United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
(OS-520)
OSWER 9938.4-03
April 1994
EPA Waste Analysis At Facilities
That Generate, Treat, Store,
And Dispose Of Hazardous Wastes
A Guidance Manual
XX
XXXX
Generation/
Treatment
Storage
Land Disposal
Printed on Recycled Paper
Waste Analysis at Facilities
That Generate, Treat, Store,
and Dispose of Hazardous Wastes
A Guidance Manual
This guidance document was developed by the U.S. Environmental Protection Agency's Office of
Waste Programs Enforcement.
NOTICE
Development of this document was funded, wholly or in part, by the United States Environmental
Protection Agency under Contract No. 68-W0-0006. It has been subjected to the Agency's review
process and approved for publication as an EPA document. Specifically, EPA Headquarters, several
EPA Regional Offices, one additional federal agency, seven state environmental agencies and/or
organizations, and nearly a dozen private companies and industry associations reviewed and submitted comments on the document.
The policies and procedures established in this document are intended solely as guidance to assist in
implementation of and compliance with promulgated regulations. They are not intended and cannot
be relied upon to create any rights, substantive or procedural, enforceable by any party in litigation
with the United States. The Agency reserves the right to act at variance with these policies and
procedures and to change them at any time with or without public notice. For example, EPA is in
the process of issuing new rules concerning the definition of hazardous waste. The new rules will
supersede those discussed in this document concerning the definition of hazardous waste. In addition, this document references the treatment standards promulgated in the Land Disposal Restrictions
regulations. These treatment standards also are subject to change by the Agency. However, regardless of changes in these existing rules, the overall format, content, procedures, and implementation
of a waste analysis plan as presented in this document will not change.
USER'S GUIDE
This guidance manual will assist facility owners and operators, as well as other facility personnel, in
preparing waste analysis plans (WAPs) and conducting waste analyses. This manual has been
designed to be useful to all facility personnel regardless of their level of experience in environmental
compliance issues. To achieve this broad application, the Introduction provides background information on the principal topics that are discussed throughout this manual, including:
•
•
•
•
•
Resource Conservation and Recovery Act (RCRA)
Land Disposal Restrictions (LDR) regulations
Waste analysis
WAPs
Purpose and organization of this manual.
The Introduction also contains a flow diagram on how to use this manual effectively. The remainder
of this manual is divided into four parts -- the contents of each part are discussed below.
Part One contains guidance on determining what your waste analysis responsibilities are for your
facility and how you can meet these responsibilities.
Part Two contains detailed guidance on documenting and conducting waste analysis once you have
identified your waste analysis responsibilities. In particular, Part Two contains guidance on important waste analysis components, including selecting the:
•
•
•
•
•
Content and organization of a WAP
Waste analysis parameters
Sampling procedures
Laboratory testing and analytical methods
Waste re-evaluation frequencies.
Part Three contains a checklist that you should reference to ensure that you have addressed all of
the waste analysis responsibilities relevant to your facility. The sections in the checklist follow the
organization developed in Part Two for preparing a WAP.
And finally, Part Four contains five sample WAPs that should be used as guides when developing
your own site-specific WAP. These sample WAPs are:
•
•
•
•
•
Generator
Generator treating to meet LDR treatment standards
On-site treatment facility -- Stabilization Unit
Off-site treatment facility -- Incineration
Landfill.
The sections in the sample WAPs also follow the organization developed in Part Two for preparing a
WAP except for sample WAPs numbers four and five, which have been reorganized slightly to
accomodate the special case where a TSDF receives waste from off site.
Proceed to the Table of Contents
iii
TABLE OF CONTENTS
Page
USER’S GUIDE ........................................................................................................................
INDEX OF APPENDICES.......................................................................................................
INDEX OF FIGURES ..............................................................................................................
INDEX OF TABLES ................................................................................................................
LIST OF ACRONYMS ............................................................................................................
iii
vii
vii
viii
x
INTRODUCTION.......................................................................................................... Introduction-1
PART ONE: RCRA AND WASTE ANALYSIS — AN OVERVIEW
1.0 How Does The RCRA Subtitle C Program Work? ..............................................
1-1
1.1 Does The RCRA Program Apply To Your Facility? ...........................................
1-2
1.2 Identifying/Classifying Hazardous Waste ...........................................................
1-3
1.3 Do You Have Any Waste Analysis Responsibilities? .........................................
1-4
1.4 What Waste Analysis Requirements Must You Meet? ........................................
1-9
1.4.1 General Waste Analysis Requirements ....................................................
1.4.2 Specific Waste Analysis Requirements ....................................................
1-9
1-10
1.5 How Can You Meet The Waste Analysis Requirements For Your Facility? ......
1-11
1.5.1 Option One: Selecting Sampling And Analysis ......................................
1.5.2 Option Two: Selecting Acceptable Knowledge ......................................
1-12
1-13
1.6 Uses Of Waste Analysis And A WAP .................................................................
1-17
1.7 Summary ..............................................................................................................
1-19
PART TWO: DOCUMENTING AND CONDUCTING WASTE ANALYSIS
2.0 Content And Recommended Organization Of A WAP .......................................
2-1
2.1 Facility Description ..............................................................................................
2-5
2.1.1 Description Of Facility Processes And Activities ....................................
2.1.2 Identification/Classification And Quantities Of
Hazardous Wastes Generated Or Managed At Your Facility...................
2.1.3 Description Of Hazardous Waste Management Units ..............................
2-5
v
2-6
2-7
2.2 Selecting Waste Analysis Parameters ..................................................................
2.2.1
2.2.2
2.2.3
2.2.4
2-8
Criteria For Parameter Selection ..............................................................
Parameter Selection Process .....................................................................
Rationale For Parameter Selection ...........................................................
Special Parameter Selection Requirements .............................................
2-9
2-11
2-11
2-11
2.3 Selecting Sampling Procedures ............................................................................
2-19
2.3.1
2.3.2
2.3.3
2.3.4
2.3.5
2.3.6
Sampling Strategies ..................................................................................
Selecting Sampling Equipment ................................................................
Maintaining And Decontaminating Field Equipment ..............................
Sample Preservation And Storage ............................................................
Establishing Quality Assurance/Quality Control Procedures ...................
Establishing Health And Safety Protocols ...............................................
2-19
2-23
2-32
2-32
2-33
2-37
2.4 Selecting A Laboratory And Laboratory Testing And Analytical Methods ........
2-39
2.4.1 Selecting A Laboratory .............................................................................
2.4.2 Selecting Testing And Analytical Methods ..............................................
2-39
2-40
2.5 Selecting Waste Re-Evaluation Frequencies .......................................................
2-44
2.6 Special Procedural Requirements ........................................................................
2-45
2.6.1 Procedures For Receiving Wastes Generated Off Site .............................
2.6.2 Procedures For Ignitable, Reactive, And Incompatible Wastes ...............
2.6.3 Procedures For Complying With LDR Requirements ..............................
2-45
2-48
2-49
2.7 Summary ..............................................................................................................
2-49
PART THREE: CHECKLIST
3.0 Checklist ..............................................................................................................
3-1
PART FOUR: SAMPLE WAPS
4.0 Introduction to Sample WAPs .............................................................................
Sample WAP #1—Generator Only .....................................................................
Sample WAP #2—Generator Treating To Meet LDR Treatment Standards ......
Sample WAP #3—On-Site Treatment Facility—Stabilization Unit ...................
Sample WAP #4—Off-Site Treatment Facility — Incinerator ...........................
Sample WAP # —Landfill ..................................................................................
vi
4-1
4-7
4-22
4-31
4-43
4-64
INDEX OF APPENDICES
APPENDIX
Appendix A:
Appendix B:
Appendix C:
Appendix D:
Appendix E:
Appendix F:
Appendix G:
Page
Hazardous Waste Identification ..................................................................................................
Regulatory Summary ...................................................................................................................
Waste Analysis Data Flow Responsibilities ................................................................................
Regulatory Citations (40 CFR §§264/265.13)
For Conducting Waste ..........................................................................................................
Analysis .......................................................................................................................................
Overview Of Major Hazardous Waste Management Units.........................................................
Glossary Of Terms ......................................................................................................................
References ...................................................................................................................................
A-1
B-1
C-1
D-1
E-1
F-1
G-1
INDEX OF FIGURES
FIGURE
I-1
1-1
1-2
2-1
2-2
2-3
2-4
2-5
2-6
2-7
2-8
2-9
2-10
2-11
4-1
4-2
4-3
4-4
4-5
4-6
4-7
4-8
4-9
4-10
4-11
4-12
4-13
4-14
4-15
4-16
4-17
4-18
Page
Guide To Using This Manual ..............................................................................................................
Hazardous Waste Identification ..........................................................................................................
Waste Analysis Data Flow ..................................................................................................................
Waste Analysis Parameter Selection Process ......................................................................................
Illustration Of Random, Stratified Random, and Systematic Sampling ..............................................
Composite Liquid Waste Sampler (Coliwasa) ....................................................................................
Weighted Bottle ...................................................................................................................................
Dipper ..................................................................................................................................................
Thief Sampler ......................................................................................................................................
Sampling Triers ...................................................................................................................................
Hand Augers ........................................................................................................................................
Example Chain-of-Custody Record ....................................................................................................
Analytical Methods Selection Flowchart ............................................................................................
Shipment Screening .............................................................................................................................
Thompson Manufacturing, Inc., Waste Generation Scenario .............................................................
Sequence Of Procedures Sets For Determining Reactivity Group ......................................................
Reactivity Group Designations and Waste Compatibility Matrix .......................................................
Schematic Of Generator Treating In 90-Day Accumulation Tanks ....................................................
Sample WAP #2 - Treatment Tank Apparatus ....................................................................................
Thompson Manufacturing, Inc., Schematic Of Waste Treatment Facility Using S/S Operations ......
Thompson Manufacturing, Inc., Schematic Of Batch S/S Treatment Process Unit............................
Sparky Incineration, Inc., Facility Layout ...........................................................................................
Sparky Incineration, Inc., Treatment System ......................................................................................
Sparky Incineration, Inc., Pre-Acceptance Procedures .......................................................................
Sparky Incineration, Inc., Incoming Waste Shipment Procedures ......................................................
Sparky Incineration, Inc., Examples Of Pre-Process, In-Process, And Post-Process
Activities Related To Decanting .....................................................................................................
Sparky Incineration, Inc., Procedures For Designating Compatible Storage Units ............................
Sparky Incineration, Inc., Hazardous Waste Sampling Flow Diagram ...............................................
Rottaway Landfill, Inc., Facility Layout .............................................................................................
Rottaway Landfill, Inc., Layout Of Each Landfill Cell .......................................................................
Rottaway Landfill, Inc., Pre-Acceptance Procedures ..........................................................................
Rottaway Landfill, Inc., Incoming Waste Shipment Procedures ........................................................
vii
Intro-7
1-5
1-8
2-12
2-22
2-25
2-26
2-27
2-28
2-29
2-30
2-38
2-43
2-46
4-15
4-20
4-21
4-27
4-30
4-36
4-40
4-52
4-53
4-55
4-56
4-59
4-60
4-62
4-70
4-71
4-73
4-74
INDEX OF FIGURES (continued)
FIGURE
4-19
A-1
Page
Procedures For Designating Compatible Storage Units .......................................................
Hazardous Waste Identification Flow Chart ........................................................................
4-75
A-2
INDEX OF TABLES
TABLE
1-1
2-1
2-2
2-3
2-4
2-5
2-6
2-7
2-8
2-9
2-10
2-11
4-1
4-2
4-3
4-4
4-5
4-6
4-7
4-8
4-9
4-10
4-11
4-12
4-13
4-14
4-15
Page
Facility Type And Waste Analysis Responsibilities ............................................................
Reference Guide To Key Issues For Consideration When Developing WAPs....................
Key Elements In Waste Analysis .........................................................................................
Description Of Listed Wastes ...............................................................................................
Description Of Characteristic Wastes ..................................................................................
Examples Of Waste Analysis Parameters ............................................................................
Sampling Approach Overview .............................................................................................
Major Sample Types.............................................................................................................
Applicability Of Sampling Equipment To Wastestreams ....................................................
Examples Of Sample Collection And Analytical Techniques: Containerization,
Preservation, And Holding Times ....................................................................................
Laboratory QC Techniques ..................................................................................................
Waste Profile Sheet ..............................................................................................................
Guide To The Sample WAPs ...............................................................................................
Scenario Overview Sample WAP #1 — Generator Only ....................................................
Scenario Overview Sample WAP #2 — Generator Treating To Meet LDR
Treatment Standards .........................................................................................................
Scenario Overview Sample WAP #3 — On-Site Treatment Facility ..................................
Scenario Overview Sample WAP #4 — Off-Site Treatment Facility ..................................
Scenario Overview Sample WAP #5 — Landfill.................................................................
Model Outline Of Sample WAPs .........................................................................................
Thompson Manufacturing, Inc., Identification/EPA Classification Of
Hazardous Wastes Generated ...........................................................................................
Thompson Manufacturing, Inc., Examples Of Criteria And Rationale For Selected...........
Parameters For Wastes Generated ........................................................................................
Thompson Manufacturing, Inc., Examples Of Waste Sampling Methods,
Equipment, And Procedures .............................................................................................
Thompson Manufacturing, Inc., Examples Of Testing/Analytical Methods For
Wastes Generated .............................................................................................................
Thompson Manufacturing, Inc., Identification/EPA Classification Of
Hazardous Wastes ............................................................................................................
Thompson Manufacturing, Inc., Criteria And Rationale For Selected
Parameters For HF Neutralization Process.......................................................................
Thompson Manufacturing, Inc., Identification/EPA Classification
Of Hazardous Wastes Treated Using S/S .........................................................................
Thompson Manufacturing, Inc., Concentration Ranges For S/S Wastes .............................
viii
1-6
2-2
2-4
2-6
2-7
2-13
2-21
2-23
2-31
2-34
2-41
2-50
4-2
4-3
4-3
4-4
4-4
4-5
4-6
4-16
4-17
4-18
4-19
4-28
4-29
4-37
4-38
INDEX OF TABLES (continued)
TABLE
4-16
4-17
4-18
4-19
4-20
4-21
4-22
4-23
4-24
4-25
4-26
4-27
Page
Thompson Manufacturing, Inc., Examples Of Testing/Analytical Methods
For S/S Wastes .................................................................................................................
Thompson Manufacturing, Inc., Criteria and Rationale For Selected Parameters ...............
Thompson Manufacturing, Inc., Frequencies Of Testing And Analysis Of S/S
Paint Sludge Wastes .........................................................................................................
Sparky Incineration, Inc., Identification/EPA Classification Of Hazardous Wastes
Treated By Incineration ...................................................................................................
Example Waste Receipt Analysis Report .............................................................................
Sparky Incineration, Inc. Fingerprint Analysis Used To Sample
Incoming Wastes ............................................................................................................
Sparky Incineration, Inc., Examples Of Selected Parameter Rationale, Criteria,
And Special Considerations ............................................................................................
Sparky Incineration, Inc., Examples Of Sampling Methods And Equipment Used ............
Rottaway Landfill, Inc., Identification/EPA Classification Of Hazardous Wastes
Managed At Rottaway Landfill .......................................................................................
Rottaway Landfill, Inc., Fingerprint Analysis Used To Sample Incoming Wastes .............
Rottaway Landfill, Inc., Selected Parameters: Rationale, Criteria, And
Special Considerations ....................................................................................................
Rottaway Landfill, Inc., Sampling Methods And Equipment ..............................................
ix
4-39
4-41
4-42
4-54
4-57
4-58
4-61
4-63
4-72
4-76
4-77
4-78
LIST OF ACRONYMS
Acronym
Definition
ASTM
BIF
Btu
CFR
CWA
DOT
DRE
EP TOX TEST
EPA
FR
H&S
HSWA
HW
LDR
mg/l
MTR
MSDS
NPDES
O/O
PCB
PFLT
POHC
ppm
QA
QC
RCRA
S/S
SW-846
American Society for Testing and Materials
Boiler and Industrial Furnace
British Thermal Unit
Code of Federal Regulations
Clean Water Act
Department of Transportation
Destruction and Removal Efficiency
Extraction Procedure Toxicity Test
Environmental Protection Agency
Federal Register
Health and Safety
Hazardous and Solid Waste Amendments
Hazardous Waste
Land Disposal Restrictions
Milligrams Per Liter
Minimum Technology Requirements
Material Safety Data Sheet
National Pollutant Discharge Elimination System
Owner and/or Operator
Polychlorinated Biphenyl
Paint Filter Liquids Test
Principal Organic Hazardous Constituent
Parts Per Million
Quality Assurance
Quality Control
Resource Conservation and Recovery Act
Stabilization/Solidification
Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods,
U.S. EPA
Solid Waste Disposal Act
Toxicity Characteristic Leaching Procedure
Total Organic Carbon
Treatment, Storage, or Disposal Facility
Total Suspended Solids
Volatile Organic Compound
Waste Analysis Plan
Wastewater Treatment Plant
SWDA
TCLP
TOC
TSDF
TSS
VOC
WAP
WWTP
x
INTRODUCTION
In the Introduction, you will be introduced to:
•
•
•
•
•
The Resource Conservation and Recovery Act (RCRA)
Land Disposal Restrictions (LDR) regulations
Waste analysis
A waste analysis plan (WAP)
The purpose and organization of this manual.
Congress passed the Solid Waste Disposal Act (SWDA) in 1965
for the primary purpose of improving solid waste disposal methods. SWDA was amended several times, most significantly by the
Resource Conservation and Recovery Act (RCRA) of 1976, and
the Hazardous and Solid Waste Amendments (HSWA) of 1984;
collectively, these acts are referred to as RCRA. RCRA was the
first federal law to address hazardous waste, and was designed to
ensure that the generation, transportation, treatment, storage, and
disposal of hazardous wastes are conducted in a manner that
protects human health and the environment.
Who Needs To Comply
With RCRA?
• Generators
• Transporters
• TSDFs
The U.S. Environmental Protection Agency (EPA) developed a
regulatory program to implement RCRA. This resulted in EPA
regulating thousands of generators, transporters, and treatment, storage, and disposal facilities (TSDFs). EPA has granted
many states the authority to operate their own state RCRA
programs in place of all or part of the federal RCRA program,
provided that these programs are at a minimum fully equivalent to,
no less stringent than, and consistent with the federal RCRA
program. In fact, state programs are often broader in scope than
the federal RCRA program (in which case the requirements that
are beyond the coverage of the federal program are not authorized
by EPA). Therefore, if your facility generates, transports, treats,
stores, or disposes of hazardous waste, you must be sure that you
are operating in compliance with all applicable state requirements, as well as any portions of the federal RCRA program that
are not covered under the EPA-approved state RCRA program.
[Note: For purposes of this manual, use of the term "RCRA
program" refers to the federal RCRA Subtitle C program and/
or an authorized state RCRA program. Similarly, the use of
"EPA" refers to the U.S. EPA and/or a state agency authorized to conduct the federal RCRA program. Federal regulations are cited in this manual. However, if your facility is in
an authorized state, the equivalent state regulations are
applicable.]
Introduction-1
What Is Waste Analysis?
Why Conduct
Waste Analysis?
•
To Determine If
Waste Is Hazardous
•
To Identify/Classify
Waste
•
To Determine Waste
Management Options
What Are The Land
Disposal Restrictions
(LDR) Regulations?
The cornerstone of the RCRA program, and the focus of this
guidance manual, is the ability of facility personnel to identify
properly, through waste analysis, all wastes that they generate,
treat, store, or dispose of. Waste analysis involves identifying or
verifying the chemical and physical characteristics of a waste
by performing a detailed chemical and physical analysis of a
representative sample of the waste or, in certain cases, by
applying acceptable knowledge of the waste (acceptable knowledge includes process knowledge and is discussed further in Part
One). You must conduct proper waste analysis to determine
whether your waste is defined as a hazardous waste under RCRA,
to identify/classify the waste according to RCRA, and to ensure
that your waste is managed properly. How your hazardous waste
is classified under RCRA will determine the legal methods
available to you for treatment, storage, or disposal of the waste.
Waste analysis, therefore, is the pivotal activity that you must
conduct properly to ensure that your facility is in compliance with
the myriad applicable regulations for proper waste treatment,
storage, or disposal. For example, waste analysis is necessary to
comply with the Land Disposal Restrictions (LDR) regulations.
HSWA required EPA to develop and implement the LDR
regulations, which apply to all persons who generate or transport
hazardous wastes as well as owners and operators of TSDFs (40
CFR Part 268). Broadly stated, the LDR regulations established treatment standards (expressed as concentration levels
or methods of treatment) for the majority of hazardous wastes
regulated under RCRA and ultimately destined for land
disposal. Most RCRA hazardous wastes are subject to the LDR
program. These wastes are known as "restricted" wastes. Restricted wastes are those RCRA hazardous wastes for which EPA
has established a treatment standard (as well as a small group of
wastes for which no treatment standards have been established but
which Congress, in HSWA, has specifically designated as ineligible for land disposal). HSWA established a series of deadlines
requiring EPA to promulgate treatment standards for groups of
hazardous wastes. EPA responded by issuing a series of
rulemakings establishing treatment standards for these hazardous
Sorry, our analysis indicates that your
waste does not meet LDR treatment
standards. You should have conducted
proper waste analysis.
STOP
Introduction-2
wastes, and effective dates for these treatment standards. Once an
effective date has passed for a given waste, LDR treatment
standards must be met before the waste can be land disposed,
unless the waste is eligible for a variance, extension, or exemption. Wastes which are eligible for a case-by-case extension (40
CFR §268.5), a no migration exemption (40 CFR §268.5), or a
national capacity variance can be land disposed without meeting
treatment standards, provided that they are disposed in a surface
impoundment or landfill that meets the minimum technological
requirements. Once a waste is restricted, at a minimum it is
subject to the waste analysis, notification, and recordkeeping
requirements of 40 CFR §268.7, even though some restricted
wastes may be eligible for land disposal without first meeting
treatment standards.
"Prohibited" wastes are a subset of restricted wastes; prohibited
wastes are those restricted wastes which are ineligible for land
disposal. Prohibited wastes have treatment standards in effect; do
not meet all treatment standards; and no extensions, exemptions,
or variances apply (see 53 FR 31208, August 17, 1988). Once a
waste has been treated to meet the applicable treatment standards,
it is no longer prohibited from land disposal, but is still subject to
the waste analysis, notification, and recordkeeping requirements
of 40 CFR §268.7. As explained above, wastes for which no
treatment standards have been promulgated, and which are not
specifically designated by HSWA as ineligible for land disposal,
are neither restricted nor prohibited, and are not currently subject
to the LDR program.
Why Is Waste Analysis
Critical To Complying With
LDR Regulations?
The LDR regulations dramatically increased the importance of
proper waste analysis to ensure that all treatment standards are
met prior to land disposal. For example, if you:
•
Generate hazardous waste, you must test the waste, or use
knowledge of the process generating the waste, to determine if the waste is restricted from land disposal. In
addition, you must notify any subsequent facilities that
will treat, store, or dispose of the waste of its LDR status.
•
Treat hazardous waste, you must test the waste to determine if treatment residues meet the established treatment
standards, and you must notify any subsequent receiving
facility of the LDR status of the waste.
•
Dispose of hazardous waste, you must test the waste to
assure that the wastes or treatment residues are in compliance with applicable LDR treatment standards before land
disposal. In addition to testing, you must have adequate
Introduction-3
documentation from the generator, treater, or storer that the
wastes meet the LDR treatment standards.
•
Store hazardous waste, you must test the waste, or use
knowledge of the waste, to determine if the waste is
restricted from land disposal. In addition, you must notify
any subsequent facilities that treat, store, or dispose of the
waste of its LDR status.
Failure to comply with the LDR regulations can result in enforcement actions against your facility.
ste
Wa is Plan
s
x
aly
xxx
An
x
xxx xxx
xxx xxxxx xxx
x
x
x xxx xxx x
xxx xxxxx xxxxx x
xxx xxxxx xxxxx x
xxx xxxxx xxxxx x
xxx xxxxx xxxxx
xxx xxxxx xx
xxx xxxxx
xxx
What Is A
Waste
Analysis Plan?
What Facilities Must
Develop A WAP?
[Note: Detailed information on LDR requirements as they
pertain to waste analysis is found in 40 CFR §268.7; and 55 FR
22669.]
A
waste analysis plan (WAP) documents the procedures
that you use to obtain a representative sample of the waste and
to conduct a detailed chemical and physical analysis of this
representative sample. The WAP also can describe special
handling procedures for proper transportation, treatment, storage,
or disposal of the wastes.
A WAP is required for all TSDFs, as well as generators
treating hazardous waste in tanks, containers, or containment buildings to meet LDR standards. Although only these
facilities are required to develop and follow a formal WAP (as
discussed further in Part One), formal documentation of waste
analysis procedures in a WAP offers every facility, whether a
generator or TSDF, many advantages, including:
•
Allowing for planning and analyzing several waste analysis options before making a selection
•
Establishing a reliable and consistent internal management mechanism for properly identifying wastes on site
•
Ensuring that all participants in waste analysis have identical information (e.g., a hands-on operating manual),
thereby promoting consistency and decreasing the likelihood that errors will be made
•
Ensuring that facility personnel changes or absences do
not lead to lost information
•
Reducing your liabilities by decreasing the instances of
improper handling or management of wastes
Introduction-4
•
A WAP Can Only Benefit
You If You Use It!
Assisting in demonstrating to EPA that you are in compliance with all regulations applicable to proper waste identification (e.g., LDR regulations), thereby ensuring a safe
operating environment and protection of human health
and the environment.
These (and other) benefits can only be realized if you use your
WAP properly!
Thus far in the Introduction, you have been introduced to the LDR regulations, waste analysis, and
the definition of a WAP -- all of which are essential
components of the RCRA program.
WAP
What Is The Purpose Of
This Manual?
The following section contains information on how to use this
manual efficiently and effectively.
Purpose And Organization Of This Guidance Manual
The purpose of this guidance manual is to provide you with
sufficient background on the RCRA program to enable you to:
first, determine whether waste analysis and WAP requirements
apply to your facility; and second, conduct waste analysis properly and develop good WAPs. To assist you in these pursuits, this
manual will achieve the following objectives:
Part One
•
Introduce you to how the RCRA regulatory program
works
•
Provide you with guidance on determining whether your
facility is regulated under RCRA as a generator or a TSDF
(this will involve determining whether the waste you
generate, treat, store, or dispose of is considered a hazardous waste under RCRA) (See also Appendix A)
•
Alert you of your responsibilities to develop a WAP and/
or conduct waste analysis (if you determine that your
facility is regulated under RCRA)
Part Two
•
Provide you with general and facility-specific guidance
on the procedures for developing a useful WAP and
conducting waste analysis
Introduction-5
Part Three
•
Provide you with a checklist to assist you in conducting
waste analysis and preparing a WAP
Part Four
•
Present five facility-specific sample WAPs.
Figure I-1 will assist you in using this manual. Figure I-1 is
designed to help you locate in the manual the information you may
need for conducting waste analysis and preparing a WAP.
This Manual Updates
The 1984 WAP Guidance
Manual And Includes:
New Regulations
NEW
REGULATIONS
•
This manual replaces the 1984 EPA manual, entitled "Waste
Analysis Plans: A Guidance Manual." This updated manual will
be of greater assistance to you because it includes information on
new federal regulations concerning waste analysis that were
promulgated since the last manual was published. The following
is a list of these regulations:
•
LDR regulations (40 CFR Part 268), including the Phase
I rule (57 FR 37194) regulating containment buildings (40
CFR Parts 264/265, Subpart DD)
•
Boiler and industrial furnace regulations (40 CFR Part
266)
•
Tank systems (40 CFR §§264.190-199 and §§265.190201)
•
Miscellaneous units (40 CFR §§264.600-603 and 265
Subpart P and Q)
•
Toxicity characteristic rule and the Toxicity Characteristic Leaching Procedure (TCLP) (40 CFR §261.24 and Part
261 Appendix II)
•
Organic air emissions from TSDFs (40 CFR Parts 264/
265 Subparts AA and BB)
•
Prohibition of liquids in landfills (40 CFR §§264/265.314).
[Note: The relevant waste analysis requirements
for each of the above referenced regulations are
summarized in Appendix B.]
•
New Waste Sampling
And Analyses
Techniques
This manual also expands on the previous version by incorporating technical advances in waste sampling and analytical methods.
Introduction-6
How Should This
Manual Be Used?
Figure I-1
Guide To Using This Manual
DRAFT WAP
STE
WA SIS
LY
ANA NCE
IDA
GU NUAL
MA
Introduction-7
Summary
In the Introduction, you reviewed the key elements
of the RCRA Subtitle C program, including LDRs,
waste analysis, and WAPs. In addition, you reviewed how to use the remainder of the manual most
efficiently.
In Part One, you will review how the RCRA program works,
determine your waste analysis responsibilities, and review your
options for meeting your responsibilities.
Proceed to Part One
Introduction-8
PART ONE:
RCRA AND WASTE ANALYSIS -AN OVERVIEW
In Part One, you will be introduced to:
•
•
•
•
•
How the RCRA Subtitle C program works
How to determine if the RCRA Subtitle C program applies to your facility
How to determine your waste analysis responsibilities
What waste analysis methods can be used to satisfy your responsibilities
Why you should always conduct waste analysis, and develop and follow a WAP.
1.0
How Are Hazardous
Waste Facilities
Regulated Under RCRA?
What Is Required In A RCRA
Permit Application?
Part A
Part B
General
Information
Detailed
Information
Including
a WAP
How Does The RCRA Subtitle C
Program Work?
T
he RCRA regulations establish administrative requirements
and facility operating standards for generators, transporters, transfer
facilities, and TSDFs. They also set technical standards for the
design and safe operation of TSDFs. To ensure that all relevant
administrative requirements, and operating and technical standards are adhered to, owners/operators of TSDFs, with few
exceptions, must apply for and obtain a RCRA Subtitle C
operating permit from EPA before operating their facility legally. The permit application covers all aspects of the design,
operation, and maintenance of a facility, and is divided into two
parts -- Part A and Part B.
Detailed requirements for Part A and Part B of the permit
application are found in 40 CFR Part 270. In summary:
•
Part A is a short, standard form that summarizes general
information about a facility, including the name of the
owner/operator, a list of the types of wastes managed at the
facility, a facility layout diagram, and the activities requiring a permit.
•
Part B is a much more extensive document, submitted in
a narrative, tabular, and schematic format, that describes
the facility operations in detail. This information is to
include, but not be limited to: a general description of the
facility; a WAP; information on the design and operation
of all hazardous waste management units; procedures to
prevent hazards; a contingency plan; and special informa1-1
tion where applicable (such as a description of the ground
water monitoring program).
Can A Facility Operate
Without A Permit?
If you are a TSDF (see Table 1-1) that was in existence on
November 19, 1980 (the effective date of the first RCRA
permitting standards), or are in existence when any new regulation is promulgated that makes your facility subject to the RCRA
program, you may be allowed to operate for an interim period
under interim status. You may operate under interim status by
filing Part A of the permit application, complying with the
notification requirements of section 3010 of RCRA (where applicable), and complying with the operating standards set in 40 CFR
Part 265. Under interim status, you are treated as "having been
issued a permit," pending EPA's decision to grant or deny the
permit application.
After receiving a completed Part B permit application, including a WAP, EPA will review the application and its components
for accuracy and completeness. Where necessary, EPA will
request additional information. Several iterations of a permit
application may be necessary before EPA will consider the
application satisfactory. When the application has been determined by EPA to be accurate and complete, EPA will prepare a
draft permit for public comment. After reviewing all comments,
EPA will make the permit decision either to grant or deny issuance
of the permit.
1.1
Does Your Facility
Generate, Treat, Store, Or
Dispose Of Hazardous
Waste?
Does The RCRA Program Apply To Your
Facility?
All generators and TSDFs are subject to the RCRA program.
Therefore, to determine whether your facility is regulated, you
must determine whether you are generating, treating, storing,
or disposing of hazardous wastes as defined by RCRA. This
is accomplished by doing one or more of the following:
•
Identifying the process that generated the waste, and the
typical waste composition from that process
•
Determining whether the waste is hazardous, per 40 CFR
Part 261
•
Conducting waste testing or analysis to verify your determination.
1-2
Even after you have determined whether RCRA applies to your
facility, you need to re-evaluate your status periodically to verify
that conditions affecting the composition of your wastes have not
changed.
1.2
How Are Hazardous
Wastes Identified/
Classified?
Identifying/Classifying Hazardous Waste
Provided below are brief RCRA statutory and regulatory definitions of hazardous waste. Hazardous wastes are a subset of solid
wastes; therefore, a material cannot be classified as a hazardous
waste if it is not within the universe of solid waste. RCRA §1004
(27) defines solid waste as:
"Any garbage, refuse, sludge from a wastewater treatment plant, or air
pollution control facility, and other discarded material, including
solid, liquid, semisolid, or contained gaseous material, resulting from
industrial, commercial, mining, and agricultural operations and from
community activities."
Statutory Definition of Hazardous Waste
The statutory definition of hazardous waste is defined in Section
1004(5) of RCRA as follows:
"A solid waste, or combination of solid waste, which because of its
quantity, concentration, or physical, chemical, or infectious characteristics may -- 1) cause, or significantly contribute to an increase in
mortality or an increase in serious irreversible, or incapacitating
reversible, illness; or 2) pose a substantial present or potential hazard
to human health or the environment when improperly treated, stored,
transported, or disposed of, or otherwise managed."
Regulatory Definition of Hazardous Waste
The RCRA statute directs EPA to develop regulations for clearly
identifying solid waste materials that satisfy this statutory definition. Consequently, the regulatory definition of hazardous waste
was published in 40 CFR Part 261 in 1980. Pursuant to 40 CFR
Part 261, solid wastes generally are defined as hazardous wastes
in two ways. First, solid wastes are hazardous wastes if they are
listed by EPA as hazardous wastes in 40 CFR Part 261 Subpart D.
Second, solid wastes are also hazardous wastes if they exhibit any
of the four characteristics found in 40 CFR Part 261 Subpart C.
These characteristics are ignitability, corrosivity, reactivity, or
toxicity (based on the Toxicity Characteristic Leaching Procedure (TCLP)). Hazardous wastes can be both listed and characteristic.
1-3
Are Your Wastes
Listed And/Or
Characteristic Wastes?
You must determine whether your wastes qualify as either listed
or characteristic wastes or both, and you must document this to
ensure compliance with all applicable regulations. Figure 1-1 can
assist you in making this hazardous waste determination.
Listed Wastes
Characteristic Wastes
Wood preservative: K001
Inorganic pigment: K002-K008
Explosives: K044-K047
and/or
Ignitable
Corrosive
Reactive
Toxic
Spent Solvents: F001-F005
(See 40 CFR Part 261 for complete account of listed wastes)
You should review these definitions as well as Appendix A of
this manual to obtain more detail on the criteria for identifying/
classifying hazardous wastes, and a methodology for determining whether the solid waste at your facility qualifies as a
hazardous waste.
Have You Identified Your
Activity (Facility) Type?
1.3
Do You Have Any Waste Analysis
Responsibilities?
If you determine that the waste at your facility is hazardous you
Generator
Treatment
Storage
Disposal
What Are
Your On-Site
Responsibilities?
then need to determine (or re-evaluate) your facility type(s) as
defined under RCRA, because the required facility operating
standards, including waste analysis requirements, vary among
generators and TSDFs. To properly identify your facility type(s),
consult the regulations set forth in 40 CFR Parts 262, 264, 265, and
270. The first two columns of Table 1-1 will assist you with this
determination.
Table 1-1 also summarizes the RCRA responsibilities, if any, of
generators and TSDFs regarding obtaining a RCRA operating
permit, identifying wastes, conducting waste analysis, and developing WAPs. Appendix B contains a more detailed summary of
applicable regulations. The responsibilities for conducting waste
analysis and preparing a WAP vary from facility to facility
depending on site-specific conditions. For example, if you are a:
•
Generator of a solid waste, pursuant to 40 CFR §262.11,
you must determine if that waste is a hazardous waste by
analyzing the waste or applying knowledge of the waste.
[Note: The RCRA regulations for these generators
(40 CFR Part 262) do not expressly refer to the term
"waste analysis" as the process of identifying, testing,
1-4
FIGURE 1-1
Figure
1-1
Hazardous Waste Identification
Hazardous Waste Identification
No
Is the material a
solid waste under 40
CFR §261.2?
Not a Hazardous Waste
Yes
Is the waste
excluded under
40 CFR §261.4?
Yes
Not a Hazardous Waste
No
Listed
No
Hazardous
Waste
• Has the waste been delisted in
accordance with 40 CFR §§260.20 and
Yes
260.22? or
• Does the mixture or derived-from residue
qualify for any of the exclusions from the
mixture and derived-from rules in 40 CFR
§261.3?
Yes
• Does the waste meet any of the listing
descriptions in 40 CFR Part 261, Subpart D? or
• Is the waste mixed with a listed hazardous
waste? or
• Is the waste derived from the treatment, storage,
or disposal of a listed hazardous waste?
No
Not a Listed
Hazardous Waste
Does the waste exhibit
a characteristic of
hazardous waste in 40
CFR Part 261, Subpart
C?*
For purposes of the Land Disposal
Restrictions program of 40 CFR Part
268, does the listed waste exhibit a
characteristic of hazardous waste in 40
CFR Part 261, Subpart C?
Yes
Listed and
Characteristic
Hazardous Waste
No
Not a Hazardous
Waste
Yes
No
Listed
Hazardous
Waste
Characteristic
Hazardous
Waste
* Note exception for mixtures of characteristic wastes and mining/mineral processing wastes in 40 CFR §261.3(a)(2)(i).
1-5
1-5
TABLE 1-1
Facility Type And Waste Analysis Responsibilities
If the Following Activities Occur at
Your Facility:
YOU ARE A …
You generate a hazardous waste at your facility and you do not treat
prohibited hazardous waste in tanks, containers, or containment buildings to
meet LDR treatment standards.
Generator
Is Hazardous
Is a RCRA
Waste
Permit
Identification
Necessary? Required?*
Waste
Analysis
Activities
No
Waste
Analysis Plan
Activities
None
You treat a prohibited hazardous waste* in tanks, containers, or containment
buildings.
You generate hazardous waste in volumes >1000 kg per month and
accumulate the waste on site for longer than 90 days.
No
You generate hazardous waste in volumes between 100 and 1000 kg per
month and accumulate the waste on-site for longer than 180** days.
You receive hazardous waste from off-site locations and store the waste in
units such as:
Storage Facility
•
•
•
•
•
containers
tanks
surface impoundments
waste piles
containment buildings
1-6
• Keep plan on site.
Make hazardous waste
determination and
conduct analysis.
You store recyclable materials on site prior to entering the recycling process.
Recycling Facility
[Note: The recycling process itself is exempt from regulation except as provided in 40 CFR
§261.6(d), and storage of the recyclable materials listed in 40 CFR §§261.6(a)(2) and (a)(3)
is not subject to the permitting requirements.]
Yes
• Follow the plan at your
site.
• Notify EPA when new
wastes are managed.
• Follow the waste analysis
requirements for your
specific treatment,
storage, or disposal unit.
Yes
You keep hazardous waste* on site 10 days or less for transfer to another
location but you do not alter the waste in any way other than bulking.
Treatment
Facility **
Disposal Facility
Transporter/
Transfer Facility
You treat hazardous waste by any number of processes, which are designed
to change the physical, chemical, or biological character or composition of the
waste so as to render the waste non-hazardous, less hazardous, safer to
transport, safer to store, safer to dispose of, or reduced in volume. Examples
of these processes and their possible associated treatment units include:
Example Process
Example Treatment Unit
Thermal Destruction
Stabilization/Solidification
Cyanide Destruction
Neutralization
Incinerator
Stabilization Unit
Tanks, containers
Tanks, containers, surface impoundments
You dispose of a hazardous waste* by means of depositing, injecting,
dumping, spilling, leaking or placing these wastes into or on any land or water
so that the waste or any of its constituents may enter the air or waters
(including groundwater).
No. (A DOT Transportation License is
necessary.)
None
None
* TSDFs may accept the generator's certification and any waste analysis data. Transporters and transfer facilities generally use the manifest to satisfy waste identification needs.
** Generators of between 100 and 1000 kg of hazardous waste per month may accumulate waste on site for up to 270 days if the off-site receiving facility is at a distance of 200 miles or more
(40 CFR §262.34(e)).
*** Certain activities that meet the definition of treatment do not require RCRA permits as listed in 40 CFR §264.1(g).
and applying knowledge of the waste to determine if
the waste is hazardous. Nonetheless, the process that
is required of generators to identify their wastes is
identical to the one required of facilities which are
expressly required to conduct waste analysis. Therefore, the term "waste analysis," as used in this manual
will refer to the process of identifying wastes per 40
CFR §262.11, and characterizing wastes per 40 CFR
§264.13 and §265.13.]
What Are Your
Responsibilities If You
Send Wastes Off Site?
•
Generator that treats a waste, that is prohibited from land
disposal, in tanks, containers, or containment buildings to
meet an LDR treatment standard, you must not only
identify your waste, and conduct waste analysis, but also
develop a written WAP and submit the plan to EPA
30 days prior to conducting treatment, pursuant to 40 CFR
§268.7.
•
TSDF with a RCRA permit or interim status, you also need
to identify your wastes, conduct waste analysis, develop a
written WAP, and submit the plan to EPA, pursuant to 40
CFR Parts 264/265.
I
n addition to conducting waste analysis and developing and
following a WAP, if required, you must forward waste analysis
information to the TSDF that subsequently receives your
waste. For example, if you are:
•
A generator of a hazardous waste who sends waste off site
for treatment, storage, or disposal, you should provide the
waste analysis information, the applicable RCRA codes
(e.g., K061), and the applicable LDR treatment standards.
In addition, the generator may provide theTSDF with a
description of the process that generated the waste. The
information will help ensure, among other things, that
your waste can be accepted according to the facility
permit.
•
An owner/operator of a treatment facility, you must provide waste analysis information (including any information supplied by the generator, as well as waste analysis
data developed by your facility before and after treatment)
to any off-site storage or disposal facility receiving the
waste to ensure that the waste is managed in compliance
with LDR requirements and their permit.
1-7
To Whom Should
You Provide Waste
Analysis Data?
•
Off-site TSDFs
•
Transfer Station
Facilities
•
Transporters
What Are Your Waste
Analysis Data Flow
Requirements?
In addition to generators and TSDFs, Table 1-1 indicates that
waste transporters and waste transfer facilities also have hazardous waste identification requirements. These facilities are not
required to conduct waste analysis or develop waste analysis
plans. However, to ensure safe handling, transporters and
transfer station owner/operators need to know the identity of
the wastes they are handling. These facilities generally rely on
the information provided by the generator or the TSDF offering
the waste as presented on the hazardous waste manifest. Therefore, the accuracy and completeness of the waste analysis performed by the generators and TSDFs is critical to them and to the
many individuals who come in contact with these materials while
they are in transit.
Figure 1-2 depicts the transfer of waste analysis information that
needs to occur among facilities. In addition, Appendix C provides a summary chart of the specific information that should be
sent by generators and TSDFs with each shipment of waste.
It is advantageous for all facilities involved to provide detailed
waste analysis information with each shipment of waste, and for
the receiving facility to verify, through waste analysis, the inforFigure 1-2
Waste Analysis Data Flow
Transfer Facility
Generator
Treatment
Facility
Storage Facility
Disposal
Facility
1-8
mation that the generator or sender of the waste provided. By
following these steps, there is an increased likelihood that the
waste will be treated, stored, or disposed of properly.
What Are Your Waste
Analysis Requirements?
General
Requirements
Specific
Requirements
1.4
What Waste Analysis Requirements Must You
Meet?
Once you have determined what your facility's waste analysis
responsibilities are (using Section 1.3), you must determine what
waste analysis regulatory requirements apply to your facility.
RCRA contains general and facility-specific waste analysis
requirements applicable to each facility type (i.e., generators
and TSDFs).
1.4.1 General Waste Analysis Requirements
What Are General Waste
Analysis Requirements?
The general requirements for conducting waste analysis are
included in:
•
40 CFR §262.11 for generators that do not treat, store, or
dispose of hazardous waste
•
40 CFR §268.7(a)(4) for generators treating in tanks,
containers, and/or containment buildings to meet LDR
treatment standards
•
40 CFR §264.13 for permitted TSDFs, including 40 CFR
§264.13(a)(4) and (c) for all off-site TSDFs (generators
who treat prohibited wastes in tanks, containers, and/or
containment buildings to meet LDR treatment requirements should also follow the general waste analysis provisions in 40 CFR §§264.13/265.13)
•
40 CFR §265.13 for TSDFs operating under interim
status.
[Note: 40 CFR §264.13 and §265.13 are included
verbatim in Appendix D of this manual.]
To meet the general waste analysis requirements, all TSDFs
should, and generators treating in tanks, containers, and/or containment buildings to meet LDR treatment standards must, obtain
a detailed chemical and physical analysis of a representative
sample of any waste that they generate, treat, store, or dispose of.
These general requirements, as documented in a WAP, are designed to ensure that you have sufficient knowledge of your
wastes to manage them properly, including identifying:
1-9
•
Procedures to ensure that the waste expected at the off-site
TSDF, if applicable, is the waste described in the manifest
•
Parameters to be analyzed
•
Sampling methods
•
Testing and analytical methods
•
Frequency for re-evaluating wastes; or frequency of spot
check or fingerprint analysis (for off-site TSDFs)
•
Acceptance/rejection criteria for each wastestream (for
off-site TSDFs).
For generators that are not treating hazardous waste in tanks,
containers, and/or containment buildings to meet LDR treatment
standards, you need only conduct waste analysis; no formal WAP
is required, although 40 CFR §262.40 imposes recordkeeping
requirements for generators performing waste analysis.
[Note: Part Two of this manual provides a full account of all
general waste analysis requirements and guidance on meeting
these requirements.]
1.4.2 Specific Waste Analysis Requirements
What Are Specific Waste
Analysis Requirements?
Operation of
Waste
Management
Units (e.g.,
tanks)
Special
Regulatory
Requirements
(e.g., LDRs)
In addition to the general waste analysis requirements, RCRA
also contains waste analysis requirements for specific waste
management methods. These requirements are different for
permitted facilities and interim status facilities [40 CFR
§264.13(b)(6) versus §265.13(b)(6)]. Specific waste analysis
requirements apply to the operation of tanks, containers, incinerators, and other specified TSDF units. Specific waste analysis
requirements also include the application of special regulatory
requirements, such as:
•
Managing ignitable, reactive, or incompatible wastes.
•
Placing bulk, containerized, or non-containerized liquid
hazardous wastes in a landfill. As of May 8, 1985,
placement of bulk or non-containerized liquid hazardous
wastes or hazardous wastes containing free liquids (whether
or not absorbents have been added) in any landfill is
prohibited. However, placement of containerized liquid
hazardous waste in a landfill is permissible under certain
conditions. For example, landfill disposal is allowed
when the containerized hazardous waste has been mixed
1-10
with a nonbiodegradable sorbent so that free-standing
liquid is no longer observed. Criteria for choosing such a
sorbent are outlined in 40 CFR §264.314(e) and
§265.314(f).
•
1.5
What Are Your
Waste Analysis Options
Under RCRA?
Sampling and
Analysis
Acceptable
Knowledge
Complying with the LDR requirements. For example,
EPA ordinarily requires that treatment and disposal facilities do independent corroborative testing (i.e., periodic
detailed physical and chemical analysis) on their waste to
ensure compliance with LDR treatment standards and
prohibitions. Treatment facilities may rely on information
provided to them by generators or treaters of the waste;
however, EPA clearly states in 55 FR 22669 that "the
restricted waste testing requirement is not superseded
by the ability of the facility to rely on information
supplied by the generator or treater." This preference
for corroborative testing, even though it arguably may be
redundant, is designed to ensure that the waste is what
others have represented it to be (even if the generator also
tested the waste or certified that it meets LDR requirements) and provides reinforcement that it will meet LDR
treatment standards prior to land disposal.
How Can You Meet The Waste Analysis
Requirements For Your Facility?
You can meet general and specific waste analysis requirements
using several methods or combinations of methods. Wherever
feasible, the preferred method to meet the waste analysis requirements is to conduct sampling and laboratory analysis because
it is more accurate and defensible than other options. (The
procedures and equipment for both obtaining and analyzing
samples are discussed in Part Two of this manual, and are
described in Appendices I and II of 40 CFR Part 261.)
However, generators and TSDFs also can meet waste analysis
requirements by applying acceptable knowledge. Acceptable
knowledge can be used to meet all or part of the waste analysis
requirements.
Acceptable knowledge can be broadly defined to include:
•
"Process knowledge," whereby detailed information on
the wastes is obtained from existing published or documented waste analysis data or studies conducted on hazardous wastes generated by processes similar to that
which generated the waste. As mentioned previously,
EPA lists (i.e., F, K, P, and U lists) certain hazardous
1-11
wastes in 40 CFR Part 261. The K-listed wastes, for example,
contain wastes generated from specific sources. Examples of K-listed wastes include:
-
K001 -- Bottom sediment sludge from the treatment
of wastewaters from wood preserving processes that
use creosote and/or pentachlorophenol.
-
K062 -- Spent pickle liquor generated by steel finishing operations of facilities within the iron and steel
industry.
K-listed wastes, therefore, are identified by comparing the
specific process that generated the waste to those processes listed in 40 CFR §261.32 (rather than conducting a
chemical/physical analysis of the waste). Similarly, any
waste described in the F, P, or U list has already been
designated as hazardous by EPA. Therefore, with many
listed wastes the application of acceptable knowledge is
appropriate because the physical/chemical makeup of the
waste is generally well known and consistent from facility
to facility.
•
Waste analysis data obtained from facilities which send
wastes off site for treatment, storage, or disposal (e.g.,
generators).
•
The facility's records of analysis performed before the
effective date of RCRA regulations. While seemingly
attractive because of the potential savings associated with
using existing information (such as published data), the
facility must ensure that this information is current and
accurate.
1.5.1 Option One: Selecting Sampling And Analysis
Compliance Is Best Ensured
Through Sampling and
Analysis
Because RCRA is a self-implementing program, the burden is on
you, the individual facility owner/operator, to demonstrate that
you are operating in compliance with all applicable regulations.
Any violations that occur at your facility, regardless of any good
faith effort you may have made to obtain information, are your
facility's sole responsibility. For example, if you own/operate
a TSDF, accept waste from an off-site facility, and rely on the
information provided by the generator or TSDF sending you
waste, your facility is still responsible for accurately identifying/classifying the waste.
1-12
When Might Full-Scale
Analysis Be Used?
When Might Fingerprint
Analysis Be Used?
Therefore, to ensure compliance with RCRA you should conduct
a full-scale, or under certain circumstances an abbreviated-scale,
sampling, and laboratory testing program for all wastes prior to
managing the wastes. Full-scale analysis (e.g., EPA's SW-846
methods or equivalent) may be necessary when:
•
A generator begins a new process or changes an existing
process
•
Wastes are received by a facility for the first time
•
A generator has not provided appropriate laboratory information to an off-site TSDF
•
An off-site TSDF has reason to suspect that the wastes
shipped were not accurately identified by the generator
•
EPA changes RCRA waste identification/classification
rules.
Abbreviated waste analysis, often referred to as “fingerprint
analysis,” is conducted generally for parameters (e.g., specific
gravity, color, flash point, presence of more than one phase, pH,
halogen content, cyanide content, percent water) that will give
information that can be used to help verify that the waste generated, or received by an off-site TSDF, matches the expected
characteristics for that waste. For example, at an off-site TSDF,
fingerprint analysis can be used to indicate that the waste received
matches the description on the manifest, and that the waste
matches the waste type that the facility has agreed to accept.
Because the owner/operator of a TSDF already knows the detailed
chemical and physical properties of a waste, the appropriate
fingerprint or spot check parameters can be chosen easily, since
the purpose of the fingerprint or spot check is only to verify that
each waste arriving at the gate of the TSDF is the actual waste
expected. The number and character of fingerprint parameters
and the criteria for acceptance/rejection of the waste will be
discussed in Part Two of this manual.
1.5.2 Option Two: Selecting Acceptable Knowledge
When Might Acceptable
Knowledge Be Used?
Generators and TSDFs may use acceptable knowledge alone or
in conjunction with sampling and laboratory analysis. As previously stated, an off-site TSDF is not relieved of its responsibility
to obtain accurate waste analysis data despite the submission of
erroneous information provided to the TSDF by the generator. As
discussed briefly on the previous page, however, there are situa
1-13
tions where it may be appropriate to apply acceptable knowledge,
including:
•
Hazardous constituents in wastes from specific processes
are well documented, such as with the F-listed and Klisted wastes.
•
Wastes are discarded unused commercial chemical products, reagents or chemicals of known physical, and chemical constituents. Several of these fall into the P-listed and
U-listed categories (40 CFR §261.33).
•
Health and safety risks to personnel would not justify
sampling and analysis (e.g., radioactive mixed waste).
•
Physical nature of the waste does not lend itself to taking
a laboratory sample. For example, to conduct waste
analysis of surface-contaminated construction debris, such
as steel girders, piping, and linoleum, it may be necessary
to use a combination of laboratory analysis and process
knowledge. The process knowledge would be applied to
identifying the composition of the base construction materials (e.g., steel). One could then collect surface "wipe"
samples and conduct laboratory analysis to determine the
representative concentrations of any contaminants present.
If the base materials are porous, such as gypsum, the
contamination could be determined by conducting analysis on the extracts obtained from a solvent wash.
Acceptable knowledge is not an appropriate substitute for fingerprint or spot check procedures except in the unique case when the
TSDF is accepting properly manifested waste from another site
owned by the same company.
Why Document
Acceptable Knowledge?
If you use acceptable knowledge in addition to or in place of
sampling and analysis, EPA, in enforcement cases, looks for
documentation that clearly demonstrates that the information
relied upon is sufficient to identify the waste accurately and
completely. Documenting both the acceptable knowledge (e.g.,
knowledge of the process that generated the F-listed or K-listed
waste) as well as any analytical data is essential for identifying
constituents applicable to LDR standards.
1-14
How Can You Verify Data
Supplied By A Generator?
Special Concerns When Using Acceptable Knowledge
There are several special concerns that you should be aware of if
you rely on acceptable knowledge to manage your wastes. First,
if you own/operate an off-site TSDF and rely, on information
supplied by a generator, you should, if possible, become thoroughly familiar with the generator's processes to verify the
integrity of the data. This can be accomplished by (1) conducting
facility visits of generators and/or (2) obtaining split samples for
confirmatory analysis. Second, if you use process descriptions
and existing published or documented data as acceptable knowledge, you should scrutinize carefully whether:
•
There are any differences between the process in the
documented data and your process
•
The published or documented data that were used are
current.
These issues are of concern, for example, because EPA recently
revised the criteria that qualify a waste as a hazardous waste due
to being characteristically toxic. Not only were the number of
constituents deemed hazardous increased, but also the prescribed
test method was modified [i.e., the TCLP replaced the Extraction
Procedure Toxicity Test (EP TOX Test)].
Why Is It Critical To
Re-Evaluate Your Use Of
Acceptable Knowledge
Periodically?
Therefore, if you have been using acceptable knowledge you need
to review your waste analysis or waste characterization data to
determine if you manage any solid wastes that are now regulated
as hazardous wastes. In addition, you need to determine if your
existing data is sufficient to identify any new constituent concentration limitations (i.e., demonstrate compliance with LDR requirements). The following examples highlight these concerns:
•
A paint manufacturer used process knowledge to identify
the hazardous waste constituents of six paint colors.
During an EPA audit, the company produced the waste
analysis documents that had been generated years earlier
and re-evaluated periodically. EPA noted that the company now manufactured eight colors. Through testing,
EPA discovered that one of the paints required barium as
a coloring agent. Barium is a metal that can render a waste
characteristically toxic (by the TCLP) if found in concentrations greater than 100 parts per million (100 ppm) per
40 CFR §261.24. This manufacturer was found to be out
of compliance because the level of barium was greater
than the maximum concentration for the toxicity charac-
1-15
teristic, and the manufacturer's waste analysis data was
inaccurate.
•
At a pulp paper mill, wastewater effluent became subject
to RCRA after the promulgation of the new toxicity
characteristic (TC) rule due to the presence of chloroforms
generated by the bleaching process in concentrations
greater than 6 ppm in an extract of the waste. Chloroform
was not regulated prior to the TC rule.
•
EPA recently promulgated an interim final rule on ignitable and corrosive wastes requiring D001 and D002
wastes that are not managed in Clean Water Act, Clean
Water Act-equivalent, or Class I Safe Drinking Water Act
systems to be treated for underlying hazardous constituents (i.e., be treated to F039 levels for F039 constituents).
An example of a waste affected by this rule is a corrosive
(D002) waste that is incinerated. When determining
which, if any, F039 constituents are present in their waste,
generators need only monitor for those F039 constituents
which are reasonably expected to be present in the waste.
Generators may rely on either knowledge of the raw
materials used, the process, and the potential reaction
products; or a one-time analysis for the entire list of F039
constituents. Subsequent analyses may then be limited to
the F039 constituents found in the initial sampling and
analysis. Off-site TSDFs should ensure that the generator's
waste analysis results and/or process descriptions are
accurate, up-to-date, and representative of the ignitable or
corrosive waste. Off-site TSDFs should also ensure that
if any changes in waste generation (e.g., a change in raw
materials used) occur, the generator re-evaluates its initial
determination of which F039 constituents are present in
the untreated waste. EPA recommends that another analysis of the F039 list of hazardous constituents be made if
such changes occur.
In addition, where documented studies are used as acceptable
knowledge, you should ensure that information is based on valid
analytical techniques. The ability of analytical equipment to
detect low concentrations of contaminants has improved over the
years and constituents that once were determined to be "nondetectable" may, in fact, be detectable using the sophisticated
equipment available today.
Although EPA recognizes that sampling and analysis are not as
economical or convenient as using acceptable knowledge, they do
usually provide advantages. Because accurate waste identifica1-16
tion is such a critical factor for demonstrating compliance with
RCRA, misidentification can render your facility liable for enforcement actions with respect to permit conditions, LDR requirements, annual reporting, and other RCRA requirements. In
addition, accurate waste analysis is critical for meeting some of
the requirements of other regulatory programs such as effluent
discharges under the Clean Water Act, and transportation requirements regulated by the Department of Transportation.
Keep Abreast Of New
Regulations And
Analytical Techniques
(e.g., LDR, TCLP)
As the above examples illustrate, you are cautioned to keep
abreast of current regulatory developments in the RCRA program
that may effect the classification of your waste, and to re-evaluate
your wastes frequently using current analytical methods and/or
process knowledge, particularly any time a rule affecting RCRA
waste identification/classification is finalized.
REFERENCE THIS MANUAL OFTEN!
(Even If You Have Obtained a Permit)
As noted previously, this manual provides you with guidance for
conducting waste analysis and developing a complete WAP.
However, even after waste analysis procedures have been
developed, documented, and implemented at your facility, and/
or you have received your RCRA operating permit, you should
refer to this manual whenever you re-evaluate your waste
analysis procedures. Re-evaluating your waste analysis procedures is necessary when:
1.6
•
Processes are changed, or other factors affecting
waste identification have occurred
•
Permits are modified or re-issued
•
Regulations affecting the definition of hazardous wastes
are promulgated, which may result in an increase in the
number, or types, of hazardous wastes managed at
your facility
•
Regulations are promulgated affecting management
of existing wastes at your facility.
Uses Of Waste Analysis And A WAP
Waste analysis and WAPs serve many critical functions for
facility personnel if written in a clear, logical, and easily reviewable
manner. Even if a facility is not required to develop a written
WAP, EPA recognizes that it may be advantageous for you to
develop one, and follow it on site because it can assist you in
1-17
demonstrating compliance with a host of RCRA requirements,
and also reduce liabilities associated with incidents which might
result from incorrect waste identification. It is important to
emphasize, however, that a WAP can only be helpful to the
extent that it is used.
What Are The Benefits
To Facility Personnel?
How Can A WAP
Help Demonstrate
Compliance To EPA?
Some of the many useful functions available to facility personnel who conduct waste analysis and use a WAP were highlighted
earlier in this manual. Additional benefits to facility personnel
include conducting proper activities relating to:
•
Ensuring waste compatibility with other waste and nonwaste materials
•
Ensuring that waste received by off-site facilities matches
the waste designated on the manifest or LDR notification
•
Responding to spills
•
Developing proper training programs for compliance with
OSHA, and developing RCRA contingency plans
•
Facilitating proper labeling and documenting wastes for
on-site management and off-site transport
•
Complying with recordkeeping requirements
•
Evaluating incidents resulting from mishaps.
WAPs also are useful to permit writers at EPA. A good WAP
will go a long way toward providing satisfaction to EPA that
appropriate RCRA concerns are met. The WAP will also assist
you in demonstrating to EPA:
•
The adequacy of your RCRA permit application, with
respect to appropriate hazardous waste treatment, storage,
and disposal methods
•
Your compliance with the LDR regulations
•
That proper waste analysis procedures are in place.
1-18
1.7
Summary
In Part One, you learned what your waste analysis
and WAP responsibilities are under the RCRA
program, and how to meet these responsibilities
(i.e., sampling and analysis, and acceptable knowledge). You also learned why it is critical that you
develop and follow a WAP and always conduct
waste analysis properly. For example, you must
develop a well-documented WAP and conduct
waste analysis properly to:
•
Ensure proper identification, treatment, storage, and disposal of hazardous wastes,
thereby avoiding permit violations and properly responding to accidents (e.g., fires and
spills)
•
Facilitate review of the permit application
(if applicable) by EPA
•
Assist in demonstrating compliance with
all applicable RCRA regulations (e.g., LDR
treatment standards) and permit operating
conditions
•
Avoid enforcement actions taken in response to inadequate waste analysis or
WAPs.
In Part Two, you will review the "nuts and bolts" of how to
prepare a WAP and conduct waste analysis.
Proceed to Part Two
1-19
PART TWO:
DOCUMENTING AND CONDUCTING
WASTE ANALYSIS
In Part One, you identified your waste analysis and WAP responsibilities, and
reviewed the methods you may use to meet these responsibilities (i.e., laboratory
testing and analysis, and acceptable knowledge). In Part Two, you will learn:
2.0
•
What information should be included in a WAP
•
How the information may be organized to facilitate easy use and review
•
How to conduct waste analysis, including selecting waste analysis parameters,
and sampling and testing methods, as well as identifying special waste
management considerations (e.g., LDR requirements).
Content And Recommended Organization Of A WAP
To facilitate conducting waste analysis and developing a WAP, Table 2-1 provides a list of key
questions arranged by facility type, that when analyzed sequentially, provide an overview of the
key elements that should be considered when planning, documenting, and conducting waste
analysis activities at your facility. Answers to the questions posed in Table 2-1 will be based on
facility-specific considerations. Relevant facility-specific factors include:
•
The type of facility (i.e., generator, storage, treatment, or disposal) and the status of the facility
(i.e., no permit is required, the facility is permitted, or the facility is operating under interim
status)
•
The characteristics and quantities of wastes generated
•
The types of units that are used to manage wastes on site.
You should also use Table 2-1 as a roadmap for using this manual. In fact, because many of the
questions are common to all facility types, they can be grouped into six major elements that all
facility types should address in their waste analysis plans. These six elements are used to
illustrate the content and recommended organization of a WAP. Table 2-2 also includes the
section of this manual in which each element is addressed, and a brief description of the guidance
that is provided for each section in this manual.
2-1
Table 2-1
Reference Guide To Key Issues For Consideration When Developing WAPs
Generators
Generator Only
1. What is the description of
the facility where wastes
are generated and/or
managed? (Section 2.1)
Treat in tanks,
containers, or
containment buildings
On-Site Only
Address all Generator
Only information, from
items 1 through 9 in
column one. In addition,
answer the following:
Address all Generator
Only information, from
items 1 through 9 in
column one. In addition,
answer the following:
Address all Generator
Only information, from
items 1 through 9 in
column one. In addition,
answer the following:
Before Treatment
Before Acceptance
2. What processes result in
Before Treatment
hazardous waste
generation? (Section 2.1)
10. What are the
3. What is the description of
applicable treatment
the hazardous wastes
standards with respect
that are generated?
to the LDR
What are the waste
regulations?
classifications, EPA
(Sections 2.1 and 2.6)
waste codes, and
treatability groups, of the After Treatment
hazardous wastes
generated? (Section 2.1) 11. Have all the LDR
treatment
standards been
4. What waste parameters
met? (Section
will be identified for
2.6)
testing, analysis, and/or
monitoring, and what is
the rationale for selecting
these parameters?
(Section 2.2.)
2-2
5. What sampling
procedures (collection
strategies, equipment,
sample preservation
methods, and QA/QC
procedures) will be
used? (Section 2.3)
6. How will a laboratory be
selected? (Section 2.4)
7. What testing and
analytical methods will
be used? (Section 2.4)
Treatment Facilities
10. What are the treatment
or process design
limitations for optimal
safe use of equipment
and materials?
(Sections 2.1 and 2.2)
What are the other
11. operational
acceptance limits
applicable to permit
and technological
considerations?
(Sections 2.1 and 2.2)
What are the
12. applicable treatment
standards with respect
to the LDR
regulations? (Section
2.6)
After Treatment
Did the treatment
13. achieve LDR
standards or is
additional sampling
and analysis
necessary to make this
determination?
(Sections 2.1, 2.2, 2.3,
2.5, and 2.6)
8. What frequency for reevaluating the waste will
be established? (Section
2.5)
What new wastes,
14. waste codes, and
treatability groups
were generated?
(Section 2.1)
9. Are additional provisions
for meeting LDR
regulations required?
(Section 2.6)
Are there any
15. additional applicable
treatment standards
with respect to LDR
regulations? (Section
2.1 and 2.6)
Off-Site Only
10. How will the identification
of wastes from off site be
verified?
(Sections 2.2, 2.5 and
2.6)
11. Will corroborative testing
be conducted using fullscale analysis,
fingerprinting, or other
process such as
acceptable knowledge?
(Sections 2.2, 2.4, 2.5
and 2.6)
12. How will wastes be
screened for
contaminants that are
incompatible with the
treatment process?
(Section 2.2)
Before Treatment
13. What are the treatment or
process design limitations
for optimum safe use of
equipment and
materials? (Sections 2.1
and 2.2)
14. What are the other
operational acceptance
limits applicable to permit
and technological
considerations? (Sections
2.1 and 2.2)
What are the applicable
15. treatment standards with
respect to LDR
regulations? (Section
2.6)
Storage Facilities
On-Site Only
Off-Site Only
Address all Generator
Only information, from
items 1 through 9 in
column one. In addition,
answer the following:
Address all Generator
Only information, from
items 1 through 9 in
column one. In addition,
answer the following:
10. Will managing wastes
(e.g., mixed bulk
chemicals) change the
chemical properties,
such that issues 13-16
must be addressed?
(Section 2.1)
How will the initial
11. waste characterization
change?
(Section 2.2)
What additional
sampling and analysis
12. are required at the
storage facility?
(Sections 2.2 and 2.3)
Will a new waste
identification be
required and how will
13. it be verified?
(Section 2.5)
What are the
applicable treatment
standards with respect
14. to LDR regulations as
a result of any
blending or mixing that
may have occurred?
(Section 2.1, 2.5, and
2.6)
Before Acceptance
10. How will the identification
of wastes from off site be
verified?
(Sections 2.5 and 2.6)
11. Will corroborative testing
be conducted using fullscale analysis,
fingerprinting or other
process such as
acceptable knowledge?
(Sections 2.2, 2.4, 2.5
and 2.6)
12. How will wastes be
screened for
contaminants that are
incompatible with the
storage process?
(Section 2.2)
After Acceptance
13. Will managing wastes
(e.g., mixed bulk
chemicals) change the
chemical properties, such
that issues 16-19 below
must be addressed?
(Section 2.1)
How will the initial waste
14. characterization change?
(Section 2.2)
What additional sampling
and analysis is required at
15. the storage facility?
(Sections 2.2 and 2.3)
Will new waste
identification be required
and how will it be
16. verified?
(Section 2.5)
Disposal Facilities
On-Site Only
Off-Site Only
Address all Generator Only
information, from items 1
through 9 in column one. In
addition, answer the
following:
Address all Generator Only
information, from items 1
through 9 in column one. In
addition, answer the
following:
Before Acceptance
10. Have all wastes
designated for land
disposal met
applicable LDR
treatment standards?
(Sections 2.1 and 2.6)
10. How will the
identification of
wastes from off site
be verified?
(Sections 2.2, 2.5 and
2.6)
Is it necessary to
conduct additional
11. (corroborative)
testing? (Sections 2.5
and 2.6)
11. How will wastes be
screened for
contaminants that are
incompatible with the
disposal process?
(Section 2.2)
After Acceptance
What type of
12. corroborative testing
will be conducted,
such as full-scale
testing and analysis,
fingerprinting, or other
process such as
acceptable
knowledge?
(Sections 2.4, 2.5,
and 2.6)
Have all wastes
received on site for
13. disposal met
applicable LDR
treatment standards?
(Sections 2.1 and 2.6)
Are additional
procedural
requirements
applicable for wastes
14. from off site?
(Sections 2.6)
Table 2-1
Reference Guide To Key Issues For Consideration When Developing WAPs
Generators
Generator Only
Treat in tanks,
containers, or
containment buildings
Treatment Facilities
On-Site Only
After Treatment (cont'd)
16. What additional
parameters of the
treated materials
(residues) will need to
be monitored, and
why? (Section 2.2)
17. How will the treated
wastes be sampled?
(Sections 2.3 and 2.4)
What testing/
18. analytical methods will
be used to analyze the
waste? (Section 2.4)
Off-Site Only
After Treatment (cont'd)
16. Did the treatment
achieve LDR standards
or is additional sampling
and analysis necessary
to make this
determination?
(Sections 2.1, 2.2, 2.3,
2.5, and 2.6)
17. What new wastes/waste
codes and treatability
groups were generated?
(Section 2.1)
Are there any additional
18. applicable treatment
standards with respect
to LDR regulations?
(Section 2.1 and 2.6)
What additional
parameters of the
19. treated materials
(residues) will need to
be monitored, and why?
(Section 2.2)
How will the treated
wastes be sampled?
20. (Section 2.3 and 2.4)
2-3
What testing/ analytical
methods will be used to
21. analyze the waste?
(Section 2.4)
Storage Facilities
On-Site Only
Off-Site Only
17. What are the
applicable treatment
standards with respect
to LDR as a result of
any blending or mixing
that may have
occurred? (Sections
2.1, 2.5, and 2.6)
Disposal Facilities
On-Site Only
Off-Site Only
Table 2-2
Key Elements In Waste Analysis
KEY ELEMENT
OF A WAP
SECTION OF
THIS MANUAL
SECTION INCLUDES
GUIDANCE ON:
Facility Description
Section 2.1
Describing important facilityspecific processes and
activities.
Selecting Waste
Analysis Parameters
Section 2.2
Identifying and selecting the
individual waste parameters for
each waste that will be
sampled and analyzed, as well
as the rationale for the
selection. 1
1
Selecting Sampling
Procedures
Section 2.3
Selecting the appropriate
sampling procedures for
effective waste
characterization. 2
Selecting a
Laboratory and
Testing and
Analytical Methods
Section 2.4
Selecting the appropriate
laboratory testing or analytical
methods. 3
Selecting Waste Reevaluation
Frequencies
Section 2.5
Determining when it is
necessary to re-evaluate the
adequacy of the waste
analysis. 4
Special Procedural
Requirements
Section 2.6
Identifying4 any special
procedures that will need to be
followed when:
2
3
- Receiving wastes generated
5
off site 5
- Ensuring safe management
of ignitable, reactive, and
incompatible wastes 66
- Demonstrating compliance
with the LDR treatment
standards. 7
7
The first five elements (Sections 2.1 through 2.5) apply to all facilities, but the sixth element
(Section 2.6, Special Procedural Requirements) applies only if you are involved in the activities
identified. For example, if you are strictly a generator, you may not be concerned with issues
related to the receipt of wastes from off-site generators. Therefore, you should review element six,
note those subsections that apply to your facility, and skip those that do not apply.
1
40
2 40
3 40
4 40
5 40
6 40
7 40
CFR §§264/265.13(b)(1)
CFR §§264/265.13(b)(3)
CFR §§264/265.13(b)(2)
CFR §§264/265.13(b)(4)
CFR §§264.265.13(c)
CFR §§264/265.13(b)(6)
CFR §§264/265.13(b)(6)
2-4
While there is no required format for a WAP, addressing these six elements in the order given generally will provide you with a document that satisfies all applicable regulations. However, EPA personnel may request additional information that is not referenced in this manual, such as site-specific data
that is necessary for the development of an effective WAP for your facility.
These six major elements are discussed in the following six sections of this manual (Sections 2.1
through 2.6). In these sections, detailed guidance is provided on how to address each of the major
elements when conducting waste analysis and developing a WAP. Where appropriate, these sections
include footnotes which designate applicable regulatory citations.
2.1
Facility Description
The facility description is an important element of an effective waste management program (including
a WAP). The facility description should provide sufficient, yet succinct, information so that implementing officials and WAP users can clearly understand the type of:
•
•
•
Processes and activities that generate or are used to manage the wastes
Hazardous wastes generated or managed
Hazardous waste management units.
These three areas are discussed separately below; your presentation of this information should be
tailored to your facility-specific conditions in a format that most clearly presents the information.
If your facility has an existing RCRA permit or is in the process of developing a permit application,
the majority of facility description information will be available from other sections of the permit.
However, it is useful to include a summary of this information in the WAP. At a minimum, the
WAP should reference where in the permit (or permit application) facility description information may be obtained.
2.1.1
Description Of Facility Processes And Activities
As a hands-on tool for ensuring compliance with applicable regulatory requirements and/or permit
conditions, the WAP should provide a description of all on-site facility processes and activities that are
used to generate or manage hazardous wastes (or reference applicable sections of the permit or permit
application). This information should include facility diagrams, narrative process descriptions, and
other data relevant to the waste management processes subject to waste analysis. As stated previously,
since many TSDFs, especially off-site facilities, utilize the WAP as an operating manual, it is advisable to incorporate process descriptions directly into the document.
In addition to describing on-site processes and activities, off-site TSDFs should reference in their
WAPs that a brief description of each generator's processes contributing wastes to the facility will be
obtained, updated, and kept on file as part of the operating record (which is reviewed by EPA/state
inspectors). If you own or operate a TSDF, this data will enhance your knowledge of off-site generation processes and, therefore, improve your ability to determine the accuracy of generator waste
classification.
2-5
2.1.2 Identification/Classification And Quantities Of Hazardous Wastes Generated Or
Managed At Your Facility
In Section 1.2 of this manual, the major concepts associated with identifying and classifying wastes
as RCRA listed or characteristic hazardous wastes were enumerated. Using these principles, the
WAP should clearly identify:
•
Each hazardous waste generated or managed at your facility
•
Each process generating these wastes
•
Rationale for identifying each waste as hazardous
•
Appropriate EPA waste classifications (e.g., EPA waste code, classification under
LDR regulations as wastewater or nonwastewater).
If you generate or manage a RCRA listed waste, you may choose, but are not required, to
present this relevant information as provided in Table 2-3.
TABLE 2-3
Description Of Listed Wastes
FACILITY
LDR
PROCESS
GENERATING
THIS WASTE
RATIONALE FOR
HAZARDOUS
WASTE
DESIGNATION
EPA
WASTE
CODE
Spent
degreasing
solvents
(trichloroethylene)
Degreasing from
machinery in Bldg.
12
Contains 25%
trichloroethylene,
cutting oils, and other
non-hazardous
degreasing solvents
F001
Wastewater
Bottom sediment
sludge
Treatment of
wastewater from
wood preserving
process
Process used
pentachlorophenol
K001
Non-wastewater
IDENTITY OF
HAZARDOUS
WASTE
WasteWater
NonWasteWater
FACILITY A
SemiConductor
Manufacturer
FACILITY B
Wood
Preserving
Facility
In addition to identifying all listed wastes generated or managed, you may need to conduct testing
and/or analysis to determine whether you also generate or manage any RCRA characteristic wastes
(e.g., for purposes of complying with LDR requirements). (A description of the sampling and analysis, including appropriate method references, that you would employ to appropriately identify characteristics is provided in Sections 2.3 and 2.4 of this manual.) If wastes are identified as characteristic,
you may choose to present relevant information as illustrated in Table 2-4.
As a supplement to the above information, this portion of the WAP also should provide a listing of
any wastes or waste properties that are known not to be manageable by the facility (i.e., inappropriate
2-6
wastes). Collectively, the identification of appropriate and inappropriate waste types will enhance the
facility's ability to develop effective sampling and analytical procedures as part of the overall waste
analysis program.
TABLE 2-4
Description Of Characteristic Wastes
FACILITY
IDENTITY OF
HAZARDOUS
WASTE
PROCESS
GENERATING
THIS WASTE
RATIONALE FOR
HAZARDOUS
WASTE
DESIGNATION
LDR
EPA
WASTE
CODE
WasteWater
NonWasteWater
FACILITY A
Pharmaceutical
Manufacturer
Toxic
Analgesic cream
(see Process #A106 or Schematic
12)
Benzene
> 0.5 ppm
D018
Wastewater
Toxic
Incineration
Waste residues
contain > 1.0 ppm
Cd
D006
Non-wastewater
FACILITY B
Hazardous
Waste
Treatment
Facility
2.1.3
Description Of Hazardous Waste Management Units
The final component of the facility description portion of the WAP should include a description of each
hazardous waste management unit at the facility. As a supplement to generic facility process and activity
discussions, these descriptions should provide more detailed information regarding the specific operating conditions and process constraints for each hazardous waste management unit.
A hazardous waste management unit is defined in the RCRA regulations as a contiguous area of land on
or in which there is significant likelihood of mixing hazardous waste constituents in the same area.7
Examples given in the regulations include:
7
8
•
Container storage areas [Note: A container alone does not constitute a unit; the unit includes
containers and the land or pad upon which they are placed.]8
•
Tanks and associated piping and underlaying containment systems
•
Surface impoundments
•
Landfills
•
Waste piles
40 CFR §260.10
40 CFR §260.10
2-7
•
Containment buildings
•
Land treatment units
•
Incinerators
•
Boilers and industrial furnaces
•
Miscellaneous units.
Appendix E contains an overview of the hazardous waste management units listed above.
In your WAP, the description of the hazardous waste management units at your facility should be provided
in narrative and schematic form. The narrative description should include the following:
2.2
•
A physical description of each management unit, including dimensions, construction materials,
and components.
•
A description of each waste type managed in each unit.
•
The methods for how each hazardous waste will be handled or managed in the unit; for example:
-
If hazardous and non-hazardous wastes will be mixed or blended, the methods for how
these activities will be conducted should be described. In certain circumstances, the
hazardous waste may continue to be regulated under the "mixture" or "derived-from"
rules. 9
-
If a surface impoundment will be used for neutralization of corrosive wastes,
the mechanism for achieving neutralization should be described.
•
Process/design considerations necessary to ensure that waste management units are operating in
a safe manner and are meeting applicable permit-established performance standards. This information
should define specific physical and chemical operating constraints that must be observed to ensure
process integrity. For example, flow injection incineration facilities typically require wastes which
have certain minimum and maximum levels of viscosity, heat content, and particulates for effective
treatment. 10
•
Prohibitions that apply to the facility (e.g., PCBs in the incinerator feed, storage of corrosive basic
waste, unpermitted RCRA hazardous waste codes).
Selecting Waste Analysis Parameters
An accurate representation of a waste's physical and chemical properties is critical in determining viable
waste management options. Accordingly, facility WAPs must specify waste parameters that provide
sufficient information to ensure:
9
10
Refer to 40 CFR §261.3(a)(2)(iv) and §261.3(c)(2)(i))
Refer to Section 2.2 of this manual for a discussion of process and design considerations as
they relate to the selection of waste analysis parameters
2-8
•
Compliance with applicable regulatory requirements (e.g., LDR regulations, newly identified
or listed hazardous wastes)
•
Conformance with permit conditions (i.e., ensure that wastes accepted for management fall
within the scope of the facility permit, and process performance standards can be met)
•
Safe and effective waste management operations (i.e., ensure that no wastes are accepted that
are incompatible or inappropriate given the type of management practices used by the facility).
Attention to the above factors when developing a WAP will orient you toward the major considerations for selecting waste analysis parameters. You should keep in mind that the parameter selection process is a repetitive process, and that you should determine final parameters in consultation with the permit writer. The following discussion provides more definitive guidance in determining specific parameters to be incorporated into your WAP.
2.2.1
Criteria For Parameter Selection
Waste analysis parameters must be selected to represent those characteristics necessary for safe and
effective waste management. Due to the diversity of hazardous waste operations and the myriad of
operating variables, the identification of the most suitable parameters to be sampled and analyzed can
be complex, especially for large TSDFs. To this point, relevant waste analysis parameter selection
criteria can be developed and reviewed systematically to efficiently identify parameters of interest.
Generally, these selection criteria may be organized into the following categories:
•
•
•
Waste identification
Identification of incompatible/inappropriate wastes
Process and design considerations.
Each major category of these selection criteria is described in detail below.
Waste Identification
A prerequisite step in proper waste management is the identification of hazardous wastes in accordance with regulatory and permit requirements. Generators and TSDFs must evaluate (through testing
or applying acceptable knowledge) solid wastes to determine if the wastes are hazardous in accordance with the RCRA characteristics and listings set forth in 40 CFR Part 261 Subparts C and D. In
addition, as a result of the LDR regulations, they must determine whether hazardous wastes are restricted from land disposal. Accordingly, an effective waste analysis plan not only specifies the
parameters necessary to ensure that wastes generated and/or accepted are accurately identified and fall
within the scope of the facility permit (where applicable), but also includes provisions to ensure that
applicable LDR requirements are fulfilled. TSDFs may consult variety of reference materials pertaining to the types of wastes to be managed when specifying parameters to corroborate waste identification under RCRA, including:
•
40 CFR Part 261, Appendices VII and VIII (i.e., the basis for listing hazardous wastes, and
hazardous constituents, respectively)
•
Industry and trade association hazardous waste profile studies
•
EPA Background Documents, for RCRA listed and characteristic hazardous wastes.
2-9
Identification Of Incompatible/Inappropriate Wastes
Regulatory requirements11 and good management practices dictate that incompatible (e.g., ignitable,
reactive) or inappropriate wastes be identified prior to waste management. If combined, incompatible wastes are capable of spontaneous combustion, toxic gas generation, or explosions. Furthermore, accepting wastestreams inappropriate for your facility operations may violate permit conditions. Examples of inappropriate wastes could include PCBs and dioxin-containing wastes. The
selection of waste parameters, therefore, must include measures to address these types of wastes.
Suitable parameters for incompatible12 and inappropriate wastes will vary according to facilityspecific operating and permit conditions. Parameters and analytical methods for ignitable and
certain reactive wastes (i.e., cyanide- and sulfide-bearing wastes) are contained in chapters seven
and eight of SW-846, respectively. The EPA document: "A Method for Determining the Compatibility of Hazardous Wastes" (EPA/600/2-80-076)13 contains guidance on evaluating qualitatively
the compatibility of various types of wastes.
Process And Design Considerations
The effectiveness of waste facility operations and associated management units are subject to both
process and equipment design limitations, which may be generically referred to as operating acceptance limits. These operating constraints determine the range of wastes and related properties that
may be managed in a given process while maintaining regulatory and permit compliance. Thus, the
facility WAP must include provisions to ensure that physical and chemical analyses provide the
information required to identify any waste properties that may exceed operating limitations. Potential risks to personnel, facility structures, and compliance status that may result from exceeding
facility operational limitations emphasize the need to identify relevant parameters affecting treatment, storage, and disposal prior to acceptance for management. Similarly, because potential
waste composition changes may occur while wastes are being managed on site, process and
design requirements impacting the selection of waste analysis parameters must be reviewed
for all phases of waste management (i.e., pre-process, in-process, and post-process). For example, where multiple treatment processes are used, waste composition changes resulting from a
pretreatment process may preclude its subsequent management by certain other hazardous waste
units at the facility.
Since operational acceptance limits determine the range of physical and chemical properties that are
acceptable for a given waste management operation, waste analysis parameters must be selected
to provide a qualitative and quantitative measure of these conditions. Typically, these waste analysis parameters are used to determine if waste properties exceed certain thresholds, which may
indicate that (1) the waste composition is atypical of that normally handled by the facility; and/or,
(2) acceptance or further management (without pretreatment) of the waste may compromise the
performance goals of the waste management process.
In addition, these waste analysis parameters must ensure that applicable regulatory requirements
and permit conditions are met while protecting waste management unit performance goals and
11
12
13
40 CFR §§264/265.17
See related discussion in Section 2.2.3
This document can be obtained from the National Technical Information Service (NTIS)
(Document No. PB-80221005).
2-10
structural integrity. Major factors to consider when identifying parameters to measure for
operational acceptance limits are listed below:
•
•
•
•
•
•
Types of waste to be managed
Volumes of waste to be managed
Method of treatment, if applicable, being employed (e.g., stabilization)
Types of units in which the wastes will be managed
Construction materials of the unit
Location of the unit.
This list is not exhaustive and, therefore, other operational factors applicable to your facility should
be considered.
2.2.2
Parameter Selection Process
As stated previously, a systematic evaluation of relevant waste analysis criteria
(i.e., those associated with waste identification, identification of incompatible/inappropriate wastes,
and process and design considerations) is useful for efficiently identifying waste parameters. To this
end, Figure 2-1 illustrates a waste analysis parameter selection process, which can be used to develop
a comprehensive inventory of waste parameters through the application of a stepped approach. Since
this tool is most useful when applied to each hazardous waste management unit individually (or each
class of units, if identical), it is envisioned that parameter selections for each unit will be developed
through separate iterations of the flow process. Concurrent with the use of the flowchart for individual operating units, attention should be given to any process variables that require different parameters according to pre-process, in-process, and post-process considerations.
To supplement the information provided in Figure 2-1, examples of commonly identified waste
analysis parameters for the major hazardous waste management units are provided in Table 2-5.
2.2.3
Rationale For Parameter Selection
Along with identifying waste analysis parameters, the RCRA regulations14 require that the WAP
provide the rationale for the selection of each parameter. The rationale must describe the basis for
the selection of the waste analysis parameter and how it will measure necessary physical and chemical waste properties to afford effective waste management within regulatory, permit, process and
design conditions. This information will provide EPA permit reviewers and WAP users with critical
information regarding the viability of parameter selection. Furthermore, the determination of the
rationale applied for each parameter is useful in determining its adequacy for incorporation into the
WAP, and may help eliminate extraneous waste analysis parameters. For reference purposes, Table
2-5 also provides the rationale for commonly selected waste analysis parameters for various waste
management units.
2.2.4
Special Parameter Selection Requirements
WAPs must also include procedures and parameters for complying with the specialized waste management regulatory requirements established for particular hazardous waste management units.
These regulatory requirements include special waste analyses for the following:
•
•
•
14
Facilities managing ignitable, reactive, or incompatible wastes
Landfills
Incinerator
40 CFR §§264/265.1(b)(1)
2-11
FIGURE 2-1
Waste Analysis Parameter Selection Process
Waste Identification
1
Proceed to Identification
of
• Incompatible/ Inappropriate
Wastes.
Process/Design
Considerations
2-12
Identify appropriate waste analysis
parameters to measure ignitability,
reactivity, and incompatibility, as
well as to identify inappropriate
wastes.
Identify the universe of parameters
that may be required to evaluate
the range of process and design
limitations.
• Determine special incompatible
waste considerations based on
facility operations and the
profile of waste being managed.
Define appropriate measurement
parameters.2
• Determine the specific parameters
necessary to identify waste
acceptability with respect to
process and design limitations,
preferably for each management
unit.
• Determine inappropriate wastes.
Define appropriate measurement
parameters.
• For pre-process, in-process, and
post-process operating variables,
select parameters which indicate
changes in waste composition that
may affect waste management
(e.g., pH, specific gravity).
• Proceed to Process/Design
Considerations.
Output
Output
•
Prioritize parameters
for incorporation into
the WAP based on
capability to provide
best representation of
waste properties.
Proceed to Parameter Evaluation.
Output
• Select appropriate waste analysis
parameters (e.g., hazardous
constituents, hazardous
characteristics) to identify
RCRA waste classification, and
LDR restricted wastes. 2
Identification of
Incompatible/
Inappropriate Wastes
Output
Identify and classify hazardous
wastes generated or managed
according to EPA waste codes.
Determine any additional
responsibilities for waste analysis
under LDR (i.e., verify whether
wastes are restricted).
Parameter Evaluation
Eliminate parameters which:
Waste Identification Parameter
Inventory.
1
Parameter
2
Identification of
Incompatible/Inappropriate
Wastes Parameter Inventory.
Process/Design Considerations
Parameter Inventory.
• Are duplicate parameters selected
during previous parameter
selection process elements.
• Cannot be measured due to
technological or other limitations.
selection can be enhanced by referencing EPA Background Documents, Appendix VII and VIII of 40 CFR Part 261, and industry/trade association waste profile studies.
Refer to the EPA document "A Method for Determining the Compatibility of Hazardous Wastes" (EPA/600/2-80-76).
TABLE 2-5
Examples Of Waste Analysis Parameters
WASTE
MANAGEMENT
UNIT TYPE
Containers
WASTE
PARAMETER(S)
• pH
• Flash Point
Tanks
Identify wastes that may compromise container
structural integrity.
Identify appropriate storage conditions (e.g., out of
direct sunlight).
• Total and Amenable
Cyanide/Sulfide
L, Sl, So
Identify potential reactivity and relevant health and
safety precautions.
• Appropriate
Hazardous
Constituent(s)
L, Sl, So
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
• pH
L, Sl
Identify wastes that may compromise structural integrity
of tanks and ancillary equipment.
L
Determine applicable requirements to treat, deactivate
or separately manage ignitable wastes to ensure
compliance with 40 CFR §§264/265.198.
• Halogens
L, Sl, So
Identify wastes with potential to corrode tanks and
ancillary equipment.
• Total and Amenable
Cyanide/Sulfide
L, Sl, So
Identify potential reactivity and relevant health and
safety precautions.
• Oxidizing Potential
L, Sl, So
Identify potential reactivity and requirements to treat,
deactivate, or separately manage reactive wastes to
ensure compliance with 40 CFR §§264/265.198.
• Appropriate
Hazardous
Constituent(s)
L, Sl, So
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
• pH
L, Sl
Identify wastes that may degrade unit structures or
systems.
• Total Suspended
Solids (TSS)
L, Sl
Identify wastes that may not be readily amenable to
pumping or unit conveyance systems.
• Flashpoint
1
L, SI
RATIONALE FOR SELECTION
L
• Flash Point
Surface
Impoundments
MEDIA
TYPE 1
L
Determine applicable requirements to treat or
deactivate ignitable wastes to ensure compliance with
40 CFR §§264/265.229.
• Oxidizing Potential
L, Sl, So
Identify potential reactivity and requirements to treat or
deactivate reactive wastes to ensure compliance with
40 CFR §§264/265.229.
• Total and Amenable
Cyanide/Sulfide
L, Sl, So
Identify potential reactivity and relevant health and
safety precautions.
• Total Chlorine
L, Sl, So
Identify wastes that may degrade liners/geotextile
integrity.
Liquid (L), Sludge (Sl), Solid (So)
2-13
2-13
TABLE 2-5
Examples Of Waste Analysis Parameters (continued)
WASTE
MANAGEMENT
UNIT TYPE
Surface
Impoundments
(continued)
Waste Piles
Land Treatment Units
WASTE
PARAMETER(S)
RATIONALE FOR SELECTION
• Total Petroleum
Hydrocarbons
L, Sl, So
Identify wastes that may degrade polypropylene
geotextiles.
• Liner Compatibility
Tests
L, Sl, So
Identify wastes that may permeate or degrade synthetic
liner materials.
• Appropriate
Hazardous
Constituent(s)
L, Sl, So
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
• pH
L, Sl
Identify wastes that may corrode unit components.
• Total Amenable
Cyanide/Sulfide
L, Sl, So
Identify potential reactivity and relevant health and
safety considerations.
• Oxidizing Potential
L, Sl, So
Identify potential reactivity and requirements to treat or
deactivate reactive wastes to ensure compliance with
40 CFR §§264/265.256.
• Ketones
L, Sl, So
Identify wastes that may degrade polyvinylchloride
(PVC) unit components. PVC integrity is degraded at
ketone concentrations above 30,000 ppm.
• Total Chlorine
L, Sl, So
Identify wastes that may degrade PVC unit
components. PVC is susceptible to selected
chlorinated aliphatics (e.g., chloroform, methylene
chloride) and chlorinated aromatics (e.g.,
chlorobenzene) at high concentrations (i.e., above
50,000 ppm).
• Liner Compatibility
Tests
L, Sl, So
Identify wastes that may permeate or degrade synthetic
liner materials.
• Appropriate
Hazardous
Constituent(s)
L, Sl, So
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
• pH
L, Sl
Identify wastes that may require pretreatment to ensure
optimum effectiveness of land treatment process.
• Total Metals
L, Sl, So
Quantify metal concentrations to ensure that rates of
application do not exceed limits specified in 40 CFR
§§264/265.276.
• Total and Amenable
Cyanide/Sulfide
L, Sl, So
Identify potential reactivity and relevant health and
safety considerations.
• Electrical Conductivity
Appropriate
• Hazardous
Constituent(s)
1
MEDIA
TYPE1
Liquid (L), Sludge (Sl), Solid (So)
L, Sl
L, Sl, So
2-14
Determine treatment performance effects from electrical
conductivity.
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
TABLE 2-5
Examples Of Waste Analysis Parameters (continued)
WASTE
MANAGEMENT
UNIT TYPE
Landfills
WASTE
PARAMETER(S)
• Free Liquid Content
(Paint Filter Liquids
Test)
• pH
Incinerators
RATIONALE FOR SELECTION
L, Sl, So
Identify the presence/absence of free liquids to ensure
compliance with 40 CFR §§264/265.314.
L, SI
Identify wastes that are not allowed to enter a landfill.
• Total Chlorine
L, Sl, So
Identify wastes that may degrade the integrity of
chlorosulfonated polyethylene landfill liners.
• Total Nitrogen
L, Sl, So
Identify wastes that may compromise chlorosulfonated
polyethylene liners.
• Liner Compatibility
Tests
L, Sl, So
Identify wastes that may permeate or degrade synthetic
liner materials.
• Total and Amenable
Cyanide/Sulfide
L, Sl, So
Identify potential reactivity and relevant health and
safety precautions.
• Chemical Compatibility
Evaluations
L, Sl, So
Identify potential incompatibilities.
• Appropriate
Hazardous
Constituent(s)
L, Sl, So
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
• Heat Content
L, Sl, So
Identify wastes that may inhibit incinerator combustion
or require blending with high-Btu wastes.
• Percent Moisture
L, Sl, So
Identify wastes with excessive moisture content.
• Ash Content
L, Sl, So
Identify wastes with high particulate content that may
compromise air emission compliance and incinerator
performance.
• Chlorine Content
L, Sl, So
Determine conformance with operational acceptance
limits for chlorine content to ensure compliance with
HCl controls under 40 CFR §§264/265.343.
L, Sl
Identify wastes that may corrode incinerator system
components.
• pH
• Total Metals
L, Sl, So
• Part 261, Appendix
VIII Constituents
L, SI, So
Identify prohibited constituents not represented by
Principal Organic Hazardous Constituents (POHCs)
selected for trial burn.
L, Sl
Identify wastes that may require blending for effective
pumping and nebalization (flow injection incinerators
only).
• Viscosity
1
MEDIA
TYPE1
Liquid (L), Sludge (Sl), Solid (So)
2-15
Identify wastes that may affect incinerator performance
or exceed permit feedstream and air emission limits.
TABLE 2-5
Examples Of Waste Analysis Parameters (continued)
WASTE
MANAGEMENT
UNIT TYPE
WASTE
PARAMETER(S)
2
RATIONALE FOR SELECTION
Incinerators
(continued)
• Appropriate
Hazardous
Constituent(s)
Boilers and Industrial
Furnaces (BIFs)
• pH
L, Sl
Identify wastes that may corrode system components.
• Viscosity
L, Sl
Identify wastes that may not be amenable to normal
conveyance systems.
• Btu Value
1
MEDIA
TYPE1
2
L, SI, So
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
L, Sl, So
Identify wastes that are prevented from management in
BIFs (i.e., <5,000 Btu/lb.).
• Ash Content
L, Sl, So
Identify wastes with high particulate content that may
compromise compliance with 40 CFR §266.105 and BIF
performance.
• Total Metals (Ag, As,
Ba, Be, Cd, Cr, Pb,
Hg, Sb, Tl)
L, Sl, So
Identify wastes that may affect BIF performance or
exceed feedstream and air emission limits in 40 CFR
§266.106.
• Chlorine Content
L, Sl, So
Determine conformance with operational acceptance
limits for chlorine content to ensure compliance with 40
CFR §266.107.
• Appropriate
Hazardous
Constituent(s)
L, SI, So
Identify constituent(s) for compliance with the permit
limits and for safe handling of the waste.
Liquid (L), Sludge (Sl), Solid (So)
Units that certify compliance with 56 FR 7183 regulations are exempted from the <5,000 btu/lb. limitation.
2-16
•
•
TSDF process vents and equipment
Boilers and industrial furnaces. 15
Sampling, analytical, and procedural methods that will be used to meet additional waste analysis
requirements for specific waste management units must be included, where applicable, in your WAP.16
For reference purposes, these special requirements are discussed below.
Ignitable, Reactive, And Incompatible Waste Analysis Requirements
WAPs must include provisions to ensure that waste management units meet the special requirements
for ignitable, reactive, and incompatible wastes.17 Incompatible wastes, if brought together, could
result in heat generation, toxic gas generation, and/or explosions. A WAP must, therefore, address
measures to identify potentially ignitable, reactive, and incompatible wastes. Standard tests to identify
ignitable wastes are contained in section 7.1 of SW-846. Although EPA does not currently have an
approved set of test procedures for reactivity, specialized methods contained in sections 7.3.3.2 and
7.3.4.2 of SW-846, respectively, have been developed to determine if a cyanide- or sulfide-bearing
waste exhibits the reactivity characteristic. Additionally, reference should be made to "Design and
Development of a Hazardous Waste Reactivity Testing Protocol" February, 1984 (EPA-600/2-84-057)
for suggested fingerprint analysis procedures. Finally, waste compatibility determinations can serve
to establish compatibility between wastes of interest for a given process. An EPA document, "A
Method of Determining the Compatibility of Hazardous Wastes" 1980 (EPA-600/2-80-076)18 , contains
procedures to evaluate qualitatively the compatibility of various categories of wastes.
Special Requirements For Bulk And Containerized Liquids In Landfills
Owners/operators of hazardous waste landfills must ensure that free liquids are not placed into the
landfill and that restrictions on containerized liquids are met.19 Specifically, bulk and/or non-containerized liquids or wastes containing free liquids may not be placed into a landfill. In addition, containers holding free liquids should not be placed in a landfill unless all free-standing liquids: (1) have been
removed by decanting, or other methods; (2) have been mixed with a nonbiodegradable absorbent or
have been solidified so that free-standing liquid is no longer observed; or (3) have been otherwise
eliminated. Limited exceptions to the placement of containers holding free liquids in landfills include:
very small containers, containers designed to hold free liquids for reasons other than storage (e.g.,
batteries, capacitors), and lab packs. You should also describe the procedures that will be used to
determine whether a biodegradable sorbent has been added to the waste in the container.
Waste Analysis Parameter Considerations For Incineration Facilities
Permitted incineration facilities must include routine analyses for prescribed waste parameters
that are required as a result of the trial burn.20 Trial burns (or comparable information) are required
before an incinerator is permitted to operate. A "trial burn plan," required for these tests, includes
analyzing each hazardous waste to be incinerated for certain hazardous constituents listed in 40 CFR
15
16
17
18
19
20
40 CFR §§264/265.17, §264.314, §§264/65.341, §§264/265.1034(d), §§264/265.1063(d),
§266l.102(a), §266.103(a).
40 CFR §§264/265.13(b)(5)
40 CFR §§264/265.17
This document can be obtained through the National technical Informatino Service
(Document No. PB-80221005).
40 CFR §§264/265.314
40 CFR §§264.341
2-17
Part 261, Appendix VIII. In almost all cases, the low concentration of hazardous waste constituents in many
wastes presents problems in the calculation of the destruction and removal efficiency (DRE). These problems
stem from the inability to attain sufficiently low detection limits in the analysis of the stack emissions in order
to calculate an acceptable DRE (i.e., 99.99 percent or higher). Therefore, in order to calculate an acceptable
DRE during a trial burn, one or more representative principal organic hazardous constituents (POHCs) are
chosen during the negotiation for the trial burn conditions. These POHCs are added to the waste (spiked) at
high concentrations. The increased concentration of the POHCs in the waste allows the use of achievable
detection limits for the stack gases for the calculation of the DRE. The calculation of an acceptable DRE is
based on a comparison of the analytical results for the selected POHCs in the stack gases and in the waste.
From this trial burn and the associated analytical information it provides, specific waste analysis parameters
will be included in the facility permit. These parameters will encompass physical and chemical measures
necessary to ensure that the composition of the incinerator waste feed meets applicable permit and operating
limits. Examples of these parameters are provided in Table 2-5.
TSDF Process Vent Analysis Requirements
TSDF owners/operators are required to identify and meet specific technical requirements for all process vents
associated with distillation, fractionation, thin-film evaporation, solvent extraction, and stripping processes
that manage wastes with a 10 ppmw (ppm by weight) or greater total organics concentration on a time
weighted annual average basis.21 The applicability of these process vent requirements is established by
measuring total organic concentrations in the waste using SW-846 Methods 9060 or 8240. The determination
that relevant processes are managing organic waste below the regulated threshold must be made as follows:
(1) by the effective date that the facility becomes subject to the requirements; and, (2) for continuously
generated wastes, annually, or whenever there is a change in the process or waste being managed.
Equipment Leak Waste Analysis Requirements
TSDF owners/operators must also determine if equipment contains or contacts organic wastes with 10 percent or greater total organic content. This trigger threshold may be determined by using the following: (1)
methods described in American Society of Testing and Materials Methods D 2267-88, E 169-87, E 260-85;
(2) Method 9060 or 8240 of SW-846; or, (3) applying knowledge of the nature of the hazardous wastestream
or the process by which it was produced. If the organic concentrations meet these regulated levels, emission
control and monitoring standards apply to each valve, pump, compressor, pressure relief device, open-ended
valve or line, flange or other connector and associated air emission control device or system.
Waste Analysis Requirements For Boilers And Industrial Furnaces
On February 21, 1991, EPA published the final rule entitled "Burning of Hazardous Waste in Boilers and
Industrial Furnaces." These regulations establish control standards for emissions of toxic organic compounds,
toxic metals, hydrogen chloride, chlorine gas, and particulate matter from the burning of hazardous wastes in
boilers and industrial furnaces (BIFs). These rules also subject owners and operators of these devices to the
general facility standards applicable to hazardous waste TSDFs, including waste analysis and WAP preparation.
To gain a RCRA permit to burn hazardous waste in BIFs, owners and operators must conduct a
trial burn to establish specific permit and operating conditions. In association with the trial burn, a
waste composition analysis must be conducted which describes the concentration of the hazardous constitu21
40 CFR §§264/265.1034(d)
2-18
ents listed in 40 CFR Part 261, Appendix VIII, for each hazardous waste to be burned in these devices.
In almost all cases, the low concentration of hazardous waste constituents in many wastes presents
problems in the calculation of the DRE. These problems stem from the inability to attain sufficiently
low detection limits in the analysis of the stack emissions in order to calculate an acceptable DRE (i.e.,
99.99 percent or higher). Therefore, in order to calculate an acceptable DRE during a trial burn, one or
more representative principal organic hazardous constituents (POHCs) are chosen during the negotiation for the trial burn conditions. These POHCs are added to the waste (spiked) at high concentrations.
The increased concentration of the POHCs in the waste allows the use of achievable detection limits for
the stack gases for the calculation of the DRE. The calculation of an acceptable DRE is based on a
comparison of the analytical results for the selected POHCs in the stack gases and in the waste. From
this trial burn and the associated analytical information it provides, specified waste analysis parameters
will be included in the facility permit. Throughout normal operation, the owner or operator must conduct sampling and analysis, as specified in the facility WAP, to ensure that hazardous waste fired into
the BIF is within the physical and chemical composition limits specified in the operating permit.
2.3
Selecting Sampling Procedures
Sampling is the physical collection of a representative portion of a universe or whole of a waste or
waste treatment residual. To be representative, a sample must be collected and handled by means that
will preserve its original physical form and composition, as well as prevent contamination or changes in
concentration of the parameters to be analyzed. For a sample to provide meaningful data, it is imperative that it reflect the average properties of the universe from which it was obtained, that its physical and
chemical integrity be maintained, and that it be analyzed within a dedicated quality assurance program.
Due to the diversity of hazardous wastes and the number of possible waste management scenarios (e.g.,
drums, roll-off boxes, tankers, lugger boxes), the type(s) of sampling procedures you will need to
employ will be variable. The following subsections discuss the proper procedures and considerations
for sample collection, sample preservation, sample shipping, quality assurance and quality control, and
occupational health and safety.
You can choose to use sampling methods specified in the regulations in 40 CFR Part 261, Appendix I,
or you may choose to petition EPA for equivalent testing and analytical methods.22 To be successful
with this petition, you must demonstrate to the satisfaction of EPA that the proposed method is equal, or
superior, to the specified method.
Only EPA-prescribed methods, referenced in Appendix I to 40 CFR 261, are discussed in this guidance
manual. These prescribed methods have two sources: the American Society for Testing and Materials
(ASTM) methods, or EPA's SW-846. In particular, SW-846 has been developed by EPA to assist the
regulated community in meeting analytical responsibilities under the RCRA program.
2.3.1
Sampling Strategies
The development and application of a sampling strategy is a prerequisite to obtaining a representative
sample capable of producing scientifically viable data. These strategies should be selected or prepared
prior to actual sampling to organize and coordinate sampling activities, to maximize data accuracy, and
22
The procedures for making this petition can be found in 40 CFR §260.21.
2-19
to minimize errors attributable to incorrectly selected sampling procedures. At a minimum, a sampling
strategy should address the following:
•
•
•
•
•
•
Objectives of collecting the samples
Types of samples needed (e.g., grab or composite)
Selection of sampling locations
Number of samples
Sampling frequency
Sample collection and handling techniques to be used.
In addition, the following factors should also be taken into consideration since they can influence the
sampling development process:
•
Physical properties of the wastes to be sampled
•
Chemical properties of the wastes to be sampled
•
Special circumstances or considerations (e.g., complex multi-phasic wastestreams,
highly corrosive liquids).23
Based upon the data objectives and considerations addressed in the sampling strategy, two major sampling approaches may be employed to collect representative samples. These approaches are summarized
as follows:
•
Authoritative Sampling - where sufficient historical, site, and process information is available to
accurately assess the chemical and physical properties of a waste, authoritative sampling (also known
as judgement sampling) can be used to obtain representative samples. This type of sampling involves
the selection of sample locations based on knowledge of waste distribution and waste properties (e.g.,
homogeneous process streams) as well as management units considerations. Accordingly, the
validity of the sampling is dependent upon the accuracy of the information used. The rationale for
the selection of sampling locations is critical and should be well documented.
•
Random Sampling - due to the difficulty of determining the exact chemical and physical properties
of hazardous wastestreams that are necessary for using authoritative sampling, the most commonly
used sampling strategies are random (not to be confused with haphazard) sampling techniques.
Generally, three specific techniques -- simple, stratified, and systematic random -- are employed.
By applying these procedures, which are based upon mathematical and statistical theories, representative samples can be obtained from nearly every waste sampling scenario. 24
Table 2-6 provides an overview of both authoritative and random sampling definitions, applicability,
and limitations. Figure 2-2 illustrates the typical sampling distribution associated with each of the
individual types of random sampling.
23
24
For complex wastes (oily sludges, multi-phasic wastes), a representative sample may require that the wastes be
homogenized prior to sampling or other techniques applied. More detailed information pertaining to the sampling of these
waste types can be obtained from the references in 40 CFR Part 261, Appendix I, your laboratory representative, or EPA
permitting officials.
For more information on statistical methods and examples of random sampling techniques, refer to EPA’s SW-846, Chapter
Nine.
2-20
TABLE 2-6
Sampling Approach Overview
SAMPLING
STRATEGY
DEFINITION
APPLICABILITY
ADVANTAGES/DISADVANTAGES
2-21
Authoritative
Technique where sample locations are
selected based on detailed knowledge
of the wastestream without regard to
randomization.
Wastestreams of known
physical/chemical properties and
concentrations.
Requires in-depth knowledge of properties and
constituents of wastestreams. Rationale for sample
selection must be well documented and defensible.
Random
(simple,
stratified,
systematic)
Techniques where sample selection
and location are determined through
the application of statistical methods.
Used to collect representative samples
where data is insufficient to justify
authoritative sampling (e.g.,
wastestreams of unknown or variable
concentration).
See discussions below for each respective random
sampling technique.
All locations/points in a waste or unit
from which a sample can be attained
are identified, and a suitable number of
samples are randomly selected.
Used to collect representative samples
of wastes that are heterogeneous
throughout the entire wastestream or
unit (e.g., multiple drums of unknown
origin).
Advantages: Most appropriate where little or no
information is available concerning the distribution of
chemical contaminants.
Areas of nonuniform properties or
concentrations are identified and
stratified (segregated). Subsequently,
simple random samples are collected
from each stratum of the waste or unit.
Used to collect representative samples
from waste or units that are known to
have areas of nonuniform properties
(strata) or concentration (hot spots)
(e.g., surface impoundment with
multiple waste layers).
Advantages: Provides for increased accuracy of
wastestream representation if strata or a typically high
or low concentration area is present.
The first sampling point is randomly
selected but all subsequent samples
are collected at fixed space intervals
(e.g., along a transect or time
intervals).
An alternate procedure used to collect
representative samples from modestly
heterogeneous wastestreams that
provides for simplified sample
identification.
Advantages: Provides for easier sample identification
and collection than other techniques.
• Simple
Random
• Stratified
Random
• Systematic
Random
Disadvantages: May misrepresent wastestreams with
areas of high concentration or stratification.
Disadvantages: Requires greater knowledge of
wastestream than for simple random sampling and
may require sophisticated statistical applications.
Disadvantages: May misrepresent wastestreams with
unknown areas of high concentration or stratification.
FIGURE 2-2
Illustration Of Random, Stratified Random, And Systematic
Sampling (e.g., Roll-off Boxes)
(axes are distance in feet)
Random Sampling
8
6
4
2
0
0
2
4
6
8
10
12
14
Stratified Random Sampling
8
6
Stratum 1
4
Stratum 2
2
0
0
2
4
6
8
10
12
14
12
14
Systematic Sampling
8
6
4
2
0
0
2
4
6
8
10
LEGEND:
Sample Area Boundary
Strata Boundary
Randomly Selected Sample Location
Sample Location Determined
Systematically
2-22
2-22
An additional element in the design of an effective sampling strategy is the selection of appropriate
sample types. Based on the desired analytical objectives of the sampling (e.g., initial waste
identification versus recharacterization), analytical considerations, and available resources (for
sampling and analysis), two basic types of samples, grab and composite, are taken in random sampling, as described in Table 2-7.
TABLE 2-7
Major Sample Types
SAMPLING
STRATEGY
GRAB
COMPOSITE
ADVANTAGES/
DISADVANTAGES
DEFINITION
APPLICABILITY
A sample taken from
a particular location
at a distinct point in
time
Most common type used
for random sampling.
Useful in determining
wastestreams variability
(e.g., range of
concentration) when
multiple or frequent
samples are obtained.
Advantages: Simplest technique, best
measure of variability.
A number of
individually collected
samples that are
combined into a single
sample for
subsequent analysis.
Used where average or
normalized concentration
estimates of a
wastestreams
constituents are desired.
Advantages: Reduces analytical costs.
May reduce the number of samples needed
to gain accurate representation of a waste.
Disadvantages: May require larger number
of samples than compositing to obtain
representative sample.
Disadvantages: Only provides the average
concentrations of a wastestream (i.e.,
information about concentration range is
lost).
A detailed description for implementing these sampling strategies and the optimum application for
each strategy are discussed in SW-846, Chapter Nine, entitled "Sampling Plan."
2.3.2
Selecting Sampling Equipment
Three broad criteria relating to the waste should be considered when determining the most appropriate type of sampling equipment to use for a given sampling strategy:
•
•
•
Physical parameters
Chemical parameters
Waste-specific (e.g., oily sludges) or site-specific factors (e.g., accessibility issues).
Specific physical parameters affecting this selection include whether the wastes are:
•
Free flowing or highly viscous liquids
•
Crushed, powdered, or whole solids
•
Contained in soil or groundwater
•
Homogeneous or heterogeneous, stratified, subject to separation with transport, or subject to
other physical alterations due to environmental factors.
2-23
Chemical parameters of the waste can also significantly affect the waste collection effort. The person
collecting the sample should ensure that the sampling equipment is constructed of materials that are not only
compatible with wastes, but are not susceptible to reactions that might alter or bias the physical or chemical
characteristics of the waste. Examples in which the sampling equipment material may potentially yield
false analytical results would be the release of organic compounds from certain plastics, or of heavy metals
(e.g., cadmium, nickel, lead) from metal alloys used in sampling corrosive wastestreams.
Waste- and site-specific factors may also affect the use of sampling devices. Examples in which unique
waste-specific properties may affect the use of common sampling equipment include the collection of oily
sludges or highly corrosive wastes. Examples of special site-specific situations involving complex sampling
activities include the collection of representative samples from waste management units with limited
accessibility. In addition to determining the type of sampling equipment used, the waste- and site-specific
factors also may require modification of the chosen equipment so that it can be applied to the waste.
Once the physical, chemical, waste- and site-specific factors associated with the wastestream to be sampled
have been identified and evaluated, appropriate sampling equipment can be selected. The equipment most
typically used in sampling includes:
•
Composite liquid waste samplers (coliwasas), weighted bottles, and dippers for liquid
wastestreams
•
Triers, thieves, and augers for sampling sludges and solid wastestreams
•
Bailers, suction pumps, and positive displacement pumps for sampling wells for groundwater
evaluations.
A coliwasa (See Figure 2-3) is most appropriate when sampling free-flowing liquids and slurries in drums,
shallow tanks, pits, and similar waste containers. The stream Coliwasa consists of a glass or metal tube
equipped with an end closure that can be opened and closed while the tube is submerged in material to be
sampled. If samples are to be taken from areas with limited accessibility, a weighted bottle or dipper (see
Figures 2-4 and 2-5, respectively) may be used to obtain a sample of a free flowing liquid or slurry.
A thief (see Figure 2-6), which consists of two slotted concentric tubes, is recommended for sampling dry
granules or powdered wastes whose particle diameter is less than one-third the width of the slots in the thief.
The outer tube has a conical pointed tip that allows the thief to penetrate the waste which is being sampled.
The inner tube can be rotated to open and close the sampler so that a sample can be collected from the waste
stream. A sampling trier (see Figure 2-7) is a tube cut in half lengthwise with a sharpened tip that allows
penetration of the tube into adhesive solids and allows granulated materials to be loosened. Generally, the
trier is 61 to 100 cm long with a diameter between 1.27 and 2.54 cm. It is used to sample solid wastes
whose diameter is less than one-half that of the trier. Augers (see Figure 2-8), which consist of sharpened
spiral blades attached to a hard metal central shaft, are used to sample hard or packed solid wastes. Augers
can be one foot to several feet long.
A more detailed description of each type of sampling equipment is presented in SW-846 Chapter Nine,
entitled "Sampling Plan." For guidance purposes, Table 2-8 presents examples of common types of sampling equipment and their applicability for sampling various types of waste streams. Waste-specific conditions at your facility may indicate that the recommended equipment in Table 2-8 is inappropriate. Accordingly, it is best to develop a sampling strategy with equipment that is tailored to your site. Consult with a
2-24
2-25
2-26
2-27
2-28
2-29
2-30
TABLE 2-8
Applicability Of Sampling Equipment To Wastestreams
Waste Location or Container
.
WASTE
TYPE
DRUM
SACKS
AND
BAGS
OPEN-BED
TRUCK
CLOSEDBED TRUCK
STORAGE
TANKS OR
BINS
PONDS,
WASTE LAGOONS,
PILES
& PITS
CONVEYOR
BELT
PIPE
2-31
Free-flowing
liquids and
slurries
Coliwasa
N/A
N/A
Coliwasa
Weighted
bottle a
N/A
Dipper
N/A
Dipper
Sludges
Trier
N/A
Trier
Trier
Trier
b
b
b
b
Moist
powders or
granules
Trier
Trier
Trier
Trier
Trier
Trier
Trier
Shovel
Dipper
Dry powders
or granules
Thief
Thief
Thief
Thief
b
Trier
Thief
Shovel
Dipper
Sand or
packed
powders and
granules
Auger
Auger
Auger
Auger
Thief
Thief
b
Dipper
Dipper
Largegrained
solids
Large
Trier
Large Trier
Large Trier
Large Trier
Large
Trier
Large
Trier
Large
Trier
Trier
Dipper
a
When the tank is adequately agitated or a recirculation line is accessible, samples can be collected through a side tap.
b
This type of sampling situation can present significant logistical sampling problems, and sampling equipment must be specifically selected or
designed based on site and waste conditions. No general statement about appropriate sampling equipment can be made.
SOURCE: SW-846
knowledgeable EPA representative, industry group, or a specialist if you are uncertain how to select the
appropriate equipment.
2.3.3
Maintaining and Decontaminating Field Equipment
Some analyses, such as pH, can be performed at the facility using field equipment. This equipment must
be properly maintained, and where appropriate, calibrated to ensure data quality from the analyses. Maintenance of equipment can include routine cleaning, oil changes, or routine replacement of worn equipment
components. The guidelines set forth in the operator's manual of each piece of equipment should be
followed since proper maintenance varies by model manufacturer. At a minimum, the equipment should
be inspected, lubricated, and calibrated prior to any field work to ensure proper operation.
All equipment that comes in contact with the waste should be free from materials which can influence (i.e.,
contaminate) the true physical or chemical composition of the waste. Therefore, all equipment and containers should be cleaned thoroughly and decontaminated prior to use. Additionally, sampling equipment
should be properly decontaminated after each sampling event. These procedures generally consist of an
initial step to remove all loose debris and soil from the sampling equipment, followed by a thorough
cleaning process including washing with an inert detergent solution (such as alconox). As a final step, the
equipment is rinsed with an appropriate solvent (e.g., volatile alcohols, acetone, or hexane for organics;
nitric acid for inorganics) followed by several rinses with deionized water.
The level of decontamination that is necessary during and after sampling is dependent upon the degree of
contamination and the sensitivity of the analytical tests to be performed. Where materials and equipment
are to be reused, proper decontamination procedures should be followed to diminish the potential for crosscontamination of samples. If subsequent storage of the equipment does not preserve the cleanliness of the
decontaminated equipment, the equipment may require additional decontamination prior to the next sampling event.
Sample containers may be supplied by a laboratory equipment manufacturer or by your analytical laboratory. For manufacturer-supplied containers, a certificate of analysis or other documentation should be
obtained which describes the contaminant levels inherent to the sample containers. In either case, appropriate quality control measures, as described in subsequent sections, should be taken. Furthermore, as a
general rule, used containers that have not been decontaminated should be avoided to reduce the potential
of cross-contamination.
2.3.4
Sample Preservation And Storage
Once the sample has been collected, sample preservation techniques, if applicable, must be employed to
ensure that the integrity of the waste remains intact while the samples are in transport to the laboratory
and/or while temporarily stored at the laboratory prior to analysis. Sample preservation is generally not
applicable for highly concentrated samples. However, low concentration samples require preservation. If
a sample is not preserved properly, the constituents of concern in the sample may be chemically, physically, or biologically altered through degradation or other processes (e.g., volatilization, oxidation). Examples of typical sample preservation techniques include the following:
2-32
•
Preserving the sample with appropriate chemicals, for example:
-
Adding sodium thiosulfate to inhibit organochlorine reactions
Adding acid preservatives to liquids containing metals
Adding acid preservatives to liquids to suppress biological activity.
• Refrigerating samples, for example:
•
Refrigerating nonliquid samples (i.e., soils, sediments, sludges)
Refrigerating liquid samples for nonvolatile organic analysis.
Storing and shipping samples in the appropriate container with an appropriate lid type,
for example:
-
Storing samples containing light sensitive organic contaminants in amber glass bottles
with teflon-lined lids
-
Storing samples of an aqueous or solid matrix intended for organic analysis in glass bottles
with teflon-lined lids (polyethylene containers are not typically appropriate for samples
intended for organic analyses because the polyethylene plastics can contribute organic
contaminants which may result in biased results)
-
Shipping and storing samples intended only for the analysis of metals and other inorganics
in glass or polyethylene bottles with polyethylene-lined lids.
Appropriate preservation methods allow samples to be stored without concern for physical or chemical
degradation for the period of time between sample collection and analysis. However, the effectiveness of
preservation diminishes over time, thereby potentially affecting the sample's integrity. Accordingly, EPA
has established standardized holding times, based upon the chemical constituent of interest, that must be
met to assure the viability of resulting analytical data. Table 2-9 gives examples of proper sample containers, preservation methods, and holding times for the analytical parameters most commonly associated with
hazardous waste evaluation. For a more detailed list of proper sample containers and preservation techniques, one should refer to SW-846.
2.3.5
Establishing Quality Assurance/Quality Control Procedures
Quality assurance (QA) is the process for ensuring that all data and the decisions based on that data are
technically sound, statistically valid, and properly documented. Quality control (QC) procedures are the
tools employed to measure the degree to which these quality assurance objectives are fulfilled. As the first
component of data acquisition in relation to waste analysis, sampling techniques should incorporate
rigorous QA/QC procedures to ensure the validity of sampling activities. Since a facility’s compliance
with applicable permitting and regulatory requirements may be based on a relatively few number of
analytical measurements, any event (e.g., unidentified contamination, dilution, improper handling) that
may compromise the acquisition of a representative sample is significant. Thus, it is important for QA/
QC procedures to be established in the WAP and stringently followed. Each facility should implement its
own QA/QC procedures because each facility will have its own unique QA/QC requirements. Additionally, all persons involved in sampling activities should be fully aware of applicable QA/QC procedures.
More detail on what is required for QA/QC is provided in SW-846.
2-33
TABLE 2-9
Examples of Sample Collection And Analytical Techniques:
Containerization, Preservation, And Holding Timesa
Matrix/Parameters
Sample Container
Preservation
Maximum
To Be Analyzed
Type and Materials
Method
Holding Time
SOLIDS:
Volatile organics (total)
Widemouth glass
w/teflon liner
Cool to 4° C
14 days
Semivolatile organics (total)
Widemouth glass
w/teflon liner
Cool to 4° C
14 days for extraction
40 days for analysis
Pesticides, herbicides, and
insecticides (total EPA scan)
Widemouth glass
w/teflon liner
Cool to 4° C
14 days for extraction
40 days for analysis
Polychlorinated biphenyls
(PCBs)
Widemouth glass
w/teflon liner
Cool to 4° C
14 days for extraction
40 days for analysis
Dioxins and furans
Widemouth glass
w/teflon liner
Cool to 4° C
14 days for extraction
40 days for analysis
Mercury (total)
Widemouth glass
w/teflon liner
Cool to 4° C
28 days for extraction
28 days for analysis
Chromium (VI)
Widemouth glass
w/teflon liner
Cool to 4° C
24 hours
All other metals (total)
Widemouth glass
w/teflon liner
None
6 months for extraction
6 months for analysis
pH
Widemouth glass
w/teflon liner
None
Analyze immediately
Total organic halogens (TOX)
Widemouth glass
w/teflon liner
Cool to 4° C
7 days
Total organic carbon (TOC)
Widemouth glass
w/teflon liner
Cool to 4° C
28 days
Toxic volatile organics, per
TC rule
Widemouth glass
w/teflon liner
Cool to 4° C
14 days for TCLP
14 days for analysis
Toxic semivolatile organics,
per the TC rule
Widemouth glass
w/teflon liner
Cool to 4° C
14 days for TCLP
7 days for extraction
40 days for analysis
TC pesticides and
herbicides
Widemouth glass
w/teflon liner
Cool to 4° C
14 days for TCLP
7 days for extraction
40 days for analysis
Concentrated Waste Samples
w/teflon liner
Widemouth glass
None
14 days
Metals (TCLP)
w/teflon liner
6 months for analysis
Widemouth Glass
Cool to 4° C
6 months for TCLP
Mercury (TCLP)
w/teflon liner
28 days for analysis
Widemouth Glass
Cool to 4° C
28 days for TCLP
a Highly concentrated samples generally do not require preservation. When chemical preservation is required, care must be taken to
ensure that incompatible preservations are not added. For example, an aqueous sample that is to be analyzed for metals should not
have acid added to it if the sample also contains cyanides.
2-34
TABLE 2-9
Examples of Sample Collection And Analytical Techniques:
Containerization, Preservation, And Holding Timesa
Matrix/Parameters
Sample Container
Preservation
Maxiumum
To Be Analyzed
Type and Materials
Method
Holding Time
LIQUIDS:
Metals (TCLP))
Widemouth glass
Cool to 4° C
6 months for TCLP
6 months for analysis
Mercury (TCLP)
Widemouth glass
Cool to 4° C
28 days for TCLP
28 days for analysis
Volatile organics
40 mL VOA Vial
Cool to 4° C; pH<2
HCl; Na2S2O3
14 days
Semivolatile organics
1 Liter Amber glass
Cool to 4° C
Na2S2O3
7 days for extraction
40 days for analysis
Pesticides, herbicides, and
insecticides
1 Liter Amber glass
Cool to 4° C
pH: 5-9
7 days for extraction
40 days for analysis
Polychlorinated biphenyls
(PCBs)
1 Liter Amber glass
Cool to 4° C
7 days for extraction
40 days for analysis
Dioxins and furans
1 Liter Amber glass
Cool to 4° C
Na2S2O3
7 days for extraction
40 days for analysis
Metals (total)
1 Liter polyethylene
Cool to 4° C
pH<2 HNO3
6 months for analysis
Mercury (total)
1 Liter polyethylene or
Widemouth glass
Cool to 4° C
pH<2 HNO3
13 days (plastic)
38 days (glass)
Chromium (VI)
500 mL Amber glass
Cool to 4° C
24 Hours
pH
Glass or polyethylene
None
Analyze immediately
Total organic halogens (TOX)
1 Liter Amber glass
Cool to 4° C
pH<2 H2SO4
7 days
Total organic carbon (TOX)
1 Liter Amber glass
Cool to 4° C; pH<2
HCl or H2SO4
28 days
Concentrated Waste
Samples
Widemouth Glass
w/teflon lines
None
14 days
a Highly concentrated samples generally do not require preservation. When chemical preservation is required, care must be taken to
ensure that incompatible preservations are not added. For example, an aqueous sample that is to be analyzed for metals should not
have acid added to it if the sample also contains cyanides.
Source: EPA’s SW-846, and Methods for Chemical
Analysis of Water and Wastes (600/4-79-020)
2-35
QA
In many ways, QA can only be measured qualitatively. For example, to assure that samples are
taken with the same level of precision each time, QA procedures can be as simple as making sure
that the personnel collecting the sample are trained and experienced. Additionally, a chain-ofcustody protocol is a useful qualitative tool for documenting the time and location of sample collection activities. The WAP should provide facility-specific procedures, including:
•
•
•
•
•
•
•
•
•
Sample strategy (including type of samples to be collected)
Sampling numbers and locations
Preservation reagents and techniques, as appropriate
Chain-of-custody procedures
Types of sampling equipment and sample containers
Analytical procedures
Decontamination procedures
Field and laboratory QC procedures (see related discussions below)
Relevant health and safety considerations.
Variations from the WAP should be documented and the reasons for deviating from WAP procedures need to be provided.
QC
QC procedures, as tools to measure the attainment of QA objectives, lend themselves to be measured
more quantitatively. For example, one QC procedure involves taking samples in duplicate or triplicate and sending them to the analytical laboratory. If the analytical results of the duplicates are
similar to the original sample, the original sample is assumed to be representative (i.e., good QA
procedures were followed). However, if sample results are highly variable, one could infer that the
sample collection procedures are not adequate for collecting a representative sample, or that one or
more of the samples collected were inadvertently contaminated. Highly variable analytical results
indicate that you should re-evaluate the sampling program (to include the collection of more
samples) or employ a different sampling strategy due to unforeseen or special site conditions.
QC measures that can be taken throughout the sampling process to ensure the integrity of the overall
program include:
•
Field Blanks - are prepared in the field by filling a clean container with pure deionized water
and appropriate preservative, if any, for the specific sampling activity being undertaken. If
contaminants are found to be present in the field blank, it might be assumed that environmental
factors (such as airborne contamination), sampling procedures (causing cross-contamination), or
equipment (that is contaminated) were contributing to the levels of hazardous waste constituents
found in the sample.
•
Trip Blanks - are sample containers that are prepared with an inert material (such as deionized
water) that are carried into and out of the field but are not opened at any time during the sampling
event. If the trip blank is found to be contaminated, the source of the contamination would be
assumed to be the container itself, the environment in which the trip blank was prepared, or some
other source located outside the sample area.
•
Equipment Blanks - are prepared prior to sampling by running pure deionized water over
sampling equipment and collecting the water into a clean sample container. If the equipment
2-36
blank is found to be contaminated, the source of contamination could be assumed to be from
the equipment used during the sampling operations.
•
Split Samples - are collected by actually splitting a sample volume in half and dispensing it
into two different containers. Typically, split samples are collected for enforcement pur
poses. The facility splits samples with the enforcement authority as a check on the facility's
own analytical program and data recordkeeping.
•
Field Duplicates - are independent samples that are taken from the same location at the same time
and are used to measure the effectiveness of obtaining representative samples. The precision
(reproducibility of analytical data) resulting from field duplicates provides an accurate reflection of
the variance inherent to the waste composition and the sampling technique.
If blanks and duplicates are collected for analysis, they should be treated as regular samples, which
would include conducting proper preservation and storage techniques as well as completing the proper
paper work (e.g., chain-of-custody documentation) accompanying the samples. The facility should
determine, based on its own data quality objectives, whether and when to collect QC samples.
Chain-Of-Custody
Chain-of-custody procedures should be specified in the WAP. These procedures involve the possession
of samples from the time they are obtained until they are disposed or shipped off site for analysis. At a
minimum, the procedures should specify that the following information be recorded when samples of
waste or treatment residuals are collected: (1) the type of waste collected, including a brief description
and the manifest number and waste code(s); (2) names and signatures of samplers; (3) sample number,
date and time of collection, and designation as a grab or composite, including what type of composite;
(4) names and signatures of any persons involved in transferring samples; and (5) if applicable, the
shipping number, such as an airbill number, for samples shipped to off-site laboratories. An example
chain-of-custody record is shown on Figure 2-9.
2.3.6
Establishing Health And Safety Protocols
Safety and health considerations should be taken into consideration when conducting sampling at your
facility. Employees who perform sampling activities must be properly trained with respect to the hazards associated with waste materials, as well as with any waste handling procedures that will assist in
protecting the health and safety of the sampler.
In addition, the employees must be trained in the proper protective clothing and equipment that must be
used when performing sampling activities. Examples of the safety procedures for which personnel at
your facility may need to be trained, depending on site-specific situations, may include:
•
Training in the common routes of exposure (inhalation, contact ingestion) that might be encountered
when taking samples
•
Instruction in the proper use of safety equipment, such as Draeger tube air samplers to detect air
contamination that employees potentially could be exposed to during sampling
•
Proper use of protective clothing and, where applicable, respiratory equipment to guard against
exposure.
2-37
FIGURE 2-9
Example Chain-Of-Custody Record
PROJECT NAME
PARAMETERS
INDUSTRIAL HYGIENE
SAMPLE
(Printed)
(Signature)
TIME
STATION LOCATION
REMARKS
NO
.O
DATE
GRAB
FIELD
SAMPLE
NUMBER
COMP
FC
ON
SAMPLERS:
TA
IN
ER
S
PROJECT NO.
2-38
Relinquished by:
(Signature)
DATE / TIME
(Printed)
Relinquished by:
(Printed)
Received by:
(Signature)
(Printed)
(Signature)
DATE / TIME
Received for Laboratory by:
(Signature)
(Printed)
Relinquished by:
(Signature)
(Printed)
DATE / TIME
DATE / TIME
Received by:
(Printed)
Remarks
(Signature)
Y
N
You are advised to consult the Occupation Safety and Health Act (OSHA), pursuant to 29 CFR
§1910.120, to determine the required training that must be given to your employees. It is optional
whether you include these procedures in your WAP. The inclusion of health and safety procedures,
however, enhances the use of the WAP as a hands-on operating tool at your facility.
2.4
Selecting A Laboratory And Laboratory Testing And
Analytical Methods
2.4.1
Selecting A Laboratory
The use of proper analytical procedures is essential to acquiring useful and accurate data. Obtaining
accurate results requires an analytical laboratory that has demonstrated experience in performing
waste sample analyses. When selecting a laboratory, preference should be given to those that are
capable of providing documentation of their proven analytical capabilities, available instrumentation,
and standard operating procedures. Furthermore, the laboratory should be able to substantiate their
data by systematically documenting the steps taken to obtain and validate the data. The following
discussion provides guidance on the factors to be considered when selecting an analytical laboratory.
The analytical laboratory that you select should exhibit demonstrated experience and capabilities in
three major areas:
•
•
•
Comprehensive QA/QC programs (both qualitative and quantitative)
Technical analytical expertise
Effective information management systems.
The relevant considerations associated with assessing laboratory strengths in each of these areas is
described in more detail below.
Comprehensive QA/QC Programs
Parallel to sampling activities, QA/QC considerations are an integral part of laboratory analytical
operations. Laboratory QA is undertaken to ensure that analytical methods generate data that are
technically sound, statistically valid, and can be documented. Individual QC procedures are the
tools employed to measure the degree to which these QA objectives are met. Accordingly, you
should ensure that the laboratory addresses the following program elements.
Qualitative QA/QC Elements
Documentation is a very important aspect of maintaining QA/QC procedures in the laboratory. An essential part of any QA program in the laboratory or in the field is the initiation of
a chain-of-custody protocol. This protocol allows tracking of the samples from collection
through data analysis and reporting. The chain-of-custody protocol for laboratories begins
with the immediate inspection of samples upon arrival for analysis and includes checking for
documentation of adherence to the proper preservation techniques, proper accompanying
paper work (e.g., chain-of-custody, shipping papers), proper sample containers, and inspection of the sample itself for signs of anomalies which could jeopardize the sample integrity
(i.e., evidence of tampering, broken containers).
The laboratory should be able to meet the established holding times for the analytical parameters of interest. Holding times that are exceeded can result in the data being judged invalid.
This can lead to the need to conduct re-sampling of the waste or EPA questioning the
facility’s compliance status. A credible laboratory will provide all the documentation neces2-39
sary, preferably in the form of a standard operating procedure (SOP), to demonstrate that
holding times for the required analyses are always met.
Quantitative QA/QC Elements
Besides the qualitative measures associated with chain-of-custody procedures, quantitative
measures should also be used by the laboratory to monitor QA/QC. These measures include
the analysis of method blanks, duplicates, matrix spikes, and surrogate spikes. Table 2-10
presents the major QC techniques used by most analytical laboratories to ensure data quality.
A well qualified laboratory will routinely employ these QA/QC procedures to evaluate the
precision and accuracy of its analytical instrumentation to determine if inadvertent contamination has occurred or if other factors exist which could affect data quality.
Technical Analytical Expertise
The analytical laboratory you select should be proficient in using the established EPA analytical
methods for hazardous waste determinations. The laboratory should also be knowledgeable of any
current developments in analytical methods that could effect data quality. To ensure that the required information regarding waste composition is provided, a good laboratory will have a working
knowledge of the regulatory levels and prescribed analytical methods for routinely analyzed contaminants (e.g., TC constituents).
When selecting an analytical laboratory, you also should consider its ability to consistently achieve
the detection limits (i.e., the lowest level of quantification possible for a given analyte) that you
request. Detection limits must be adequate to ensure sufficiently low levels of parameter identification to meet prescribed regulatory or permitting thresholds. The importance of these considerations
is illustrated effectively by laboratories that are equipped with only limited or outdated analytical
instrumentation. These operations may be incapable of meeting more stringent analytical requirements established in recent regulations such as the TC rule or recently promulgated LDR requirements, and thereby compromise your ability to validate compliance with applicable waste management requirements.
Information Management
Finally, the laboratory should maintain effective information management systems. These systems
are necessary to ensure the availability of all relevant data generated in association with a given
sample set (e.g., chain-of-custody records, accuracy and precision information, and analytical results). Additionally, all analytical reports provided should present information in a clear and concise
manner. A credible laboratory will work with you to tailor its reports to meet your specific requirements. This is advantageous to assure that you use the information correctly to verify regulatory
compliance or to evaluate process performance. The laboratory also should be able to provide the
information needed to prove data validation (i.e., QA/QC documentation).
2.4.2
Selecting Testing And Analytical Methods
To be useful in sustaining regulatory and permit compliance, the WAP must specify testing and
analytical methods which are capable of providing reliable data to ensure safe and effective waste
management. The selection of an appropriate methodology is dependent upon the following considerations:
•
•
•
Physical state of the sample (e.g., solid or liquid)
Analytes of interest (e.g., volatile organics)
Required detection limits (e.g., 1/5 to 1/2 of the regulatory thresholds)
2-40
TABLE 2-10
Laboratory QC Techniques
QC TECHNIQUE
2-41
PURPOSE
DESCRIPTION
RATE
Method Bank
Ensure that any contamination
resulting from analytical
equipment or process is
identified.
Method blanks are artificial samples, usually
comprised of distilled deionized water, that are
submitted to the same laboratory preparation
and analytical process as your samples. If any
contaminants are present in this artificial
sample after preparation and analysis, it can be
inferred that previous samples or laboratory
practices caused erroneous or biased results.
Performed at least once with
each analytical batch with a
minimum of once per 20
samples.
Duplicates
Evaluate the precision of the
analytical process.
Two samples of the waste are obtained from
one sample container and both are subjected
to the same preparation and analysis.
Performed at least once with
each analytical batch with a
minimum of once per 20
samples.
Matrix Spike
Evaluate the efficiency,
accuracy, and precision of the
method being employed to
analyze the samples.
Compounds of interest are "spiked" (added)
into the sample prior to any preparation
methods. The recoveries of the spiked
compounds are then used to evaluate the
efficiency of the method in detecting the
compounds of interest.
Performed at least once with
each analytical batch with a
minimum of once per 20
samples.
Certified Reference
Material
Evaluate the methods' efficiency
and accuracy.
A sample of known analyte composition and
concentration that is used as a benchmark
standard.
Performed at least once with
each analytical batch with a
minimum of once per 20
samples.
Surrogate Spikes
Evaluate the methods' efficiency
and accuracy.
Organic compounds which resemble the
analytes of interest in chemical composition,
extraction properties, and chromatographic
properties. The recovery of the surrogate spike
is used to indicate the effectiveness of the
analytical process.
Performed at least once with
each analytical batch with a
minimum of once per 20
samples.
•
Information requirements (e.g., detection monitoring, verify compliance with LDR treatment standards).
Analytical methods consist of two distinct phases -- a preparation phase and a determination phase. The use
of an appropriate combination of preparation and determination procedures is necessary to ensure the accuracy
of data generated from your facility waste management program.
Preparation Phase
Preparation methods are selected based upon a consideration of the factors presented above in section 2.4.2 as
well as any special requirements associated with the type of analytical determination being performed. These
procedures are designed primarily to accomplish one or more of the following:
•
•
•
•
Extract the analytes of interest from the sample matrix
Adjust physical properties (e.g., pH)
Facilitate chemical conversions necessary for analysis
Concentrate analytes to allow trace determinations.
Some samples intended for organics analysis that are either highly contaminated or contain extraneous contaminants that are capable of adversely affecting the analysis may require an additional procedure, known as a
cleanup step, during sample preparation. These cleanup procedures remove potential interferences from the
sample, thereby making it more amenable to subsequent analysis. The most common organic chemical cleanup
procedures are florisil column, silica gel column, or gel permeation. The decision to perform a cleanup step
usually is made by the analytical laboratory and often involves sophisticated technical judgements concerning
sample composition, chemical interactions, and specific analytical limitations. Therefore, this manual will only
reference sample cleanup procedures that may be used. If more information is required on the application of a
particular cleanup method, the information can be obtained from SW-846.
Determination Phase
The application of a sample preparation method and, where required, a cleanup step, should be accompanied by
an appropriate determination procedure specific to the analyte of interest. Analytes are divided into classes
(e.g., metals, volatile organic compounds), and for each analytical class, a standard method has been developed
to identify and quantify them. For example, organic compounds are typically analyzed by gas chromatography
(GC) or gas chromatography-mass spectroscopy (GC-MS), while metals are analyzed by atomic absorption
spectroscopy (AA) or inductively coupled argon plasma (ICAP) spectroscopy.
Due to the number of available preparation and determination options, Figure 2-10 is presented to facilitate the
selection of the most appropriate preparation and analytical methods to use when performing waste analysis.
For both inorganic and organic determinations, this figure provides the recommended SW-846 methods to be
employed in the analysis of hazardous wastes for hazardous waste constituents (i.e., Part 261, Appendix VIII).
In addition to SW-846, the following references provide information on approved methods for analyzing waste
samples:
•
American Society for Testing and Materials (ASTM)
•
"Design and Development of a Hazardous Waste Reactivity Testing Protocol," U.S. Environmental
Protection Agency, EPA Document No. 600/2-84-057 (February 1984)
•
"The Toxicity Characteristic Rule" (55 FR 11862)
2-42
FIGURE 2-10
EPA Designated (SW-846) a
Analytical Methods Selection Flowchart
SAMPLE
Inorganic
Analysis
(Metals)
Sample
Preparation
Aqueous
3010
Solids
3050
Inorganic
Mercury
7470 (liquids)
7471 (solids)
Selenium
7740
Aqueous
3510/3520
Solid
3540/3550
Oils
3580
Is Cleanup
Needed?
Chromium VI
7196/7197
a
Volatile
Sample
Preparation
Aqueous, Solid,
Sludge, and Oil
5030
Sludge
3520
No
Yes
SAMPLE CLEANUP:
Alumina Column
Alumina for Petroleum
Florisil Column
Silica Gel Column
Gel Permeation
Acid Base Partitioning
Sulfur
GC/MS Analysis
8250/8270
Organic
Analysis
SemiVolatile
Sample
Preparation
Arsenic
7060
Inductively
Atomic Absorption
Coupled Plasma Analysis 7000 Series
Analysis 6010
Flame and Furnace
Organic
Analytical
Determination
GC ANALYSIS:
Phthalate Esters
Organochlorine Pesticides and PCB's
Polynuclear Aromatic Hydrocarbons
Chlorinated Hydrocarbons
Organophosphorous Pesticides
Chlorinated Herbicides
8060
8080
8100
8120
8140
8150
3610
3611
3620
3630
3640
3650
3660
GC/MS Analysis
8240
GC ANALYSIS:
Halogenated Volatile Organics
Nonhalogenated Volatile Organics
Aromatic Volatile Organics
Acrolein, Acrylonitrile, Acetonitrile
Test Methods for Evaluating Solid Wastes, SW-846, Third Edition and Updates. Numbers in the boxes are the
SW-846 Method numbers.
2-43
2-43
8010
8015
8020
8030
•
"Methods for Chemical Analysis of Water and Wastes", EPA Document No. 600/479-020 (Revised March 1983).
When identifying potential analytical methods to incorporate into your WAP, you can choose to use methods specified in SW-846 and other documents such as ASTM methods, or when an EPA method is required, such as determining whether a waste is corrosive or exhibits the toxicity characteristic, you can
choose to petition to use an equivalent analytical method. To be successful with this petition, you must
demonstrate to the satisfaction of EPA that the proposed method is equal to or superior to the method
specified in the regulations. The procedures for making such a petition can be found in 40 CFR §260.21.
[NOTE: Chapter One of SW-846 describes Data Quality Objectives (DQOs) as the overall level of uncertainty that a decision maker is willing to accept in the results derived from environmental data. This level
of uncertainty is used to specify the quality of the measurement data required, usually in terms of objectives
for precision, bias, representativeness, comparability, and completeness. DQOs should be established
before the initiation of field or laboratory work. Please refer to Chapter One of SW-846 for more detail.]
2.5
Selecting Waste Re-Evaluation Frequencies
The RCRA regulations state that "waste analysis must be repeated as often as necessary to ensure that it is
accurate and up to date."25 At a minimum, the analysis must be repeated as follows:
•
When the TSDF is notified, or has reason to believe that the process or
operation generating the hazardous wastes has changed26
•
When the generator has been notified by an off-site TSDF that the characterization
of the wastes received at the TSDF does not match a pre-approved waste analysis
certification and/or the accompanying waste manifest or shipping paper (the
generator may be requested to re-evaluate the waste).27
•
Off-site combustion facilities should characterize all wastes prior to burning to
verify that permit conditions will be met (i.e., fingerprint analysis may not
be acceptable).
Although there are no required time intervals for re-evaluating wastes, you must develop a schedule for reevaluating the waste on a regular basis. You will need to make an individual assessment of how often the
wastes analysis is necessary to ensure compliance with your interim status or Part B permit operating
conditions.
Off-site TSDFs will want to be particularly thorough in developing a schedule for re-evaluating wastes that
will (1) confirm that the information provided by the generator is correct, and (2) detect any changes in the
waste properties while managing the waste. When receiving wastes from off-site generators, conducting
corroborative testing and or analysis will provide added protection. It is common practice for TSDFs that
receive wastes from an off-site generator (or other facility) to require the submittal of a Waste Profile Sheet
(or comparable document) to the TSDF as a pre-acceptance condition. A Waste Profile Sheet provides a
comprehensive description of each wastestream. An example Waste Profile Sheet is provided as Table 211, located at the end of Part Two. Additionally, the TSDF may request that the generator also provide a
representative sample of the waste to be analyzed by the TSDF, to confirm the generator's waste profile
description.
Most facilities that receive wastes from off site sample a percentage of the wastes when they are received,
25
26
27
40 CFR §§264.13(a)(3)/265.13(a)(3)
40 CFR §264.13(a)(3)(i)
40 CFR §264.13(a)(3)(ii)
2-44
and check each waste container for "selected fingerprint analysis parameters." Fingerprint analyses
are used to provide an indication of whether the waste has been accurately identified by the generator
on the hazardous waste manifest, LDR notification/certification, pre-acceptance contract or other
documentation. Choosing the appropriate fingerprint analysis parameters requires facility-specific
determinations based on several factors that are discussed in detail in the next section (i.e.,
Section 2.6).
Fingerprint analysis is never a substitute for conducting a complete waste analysis and, therefore, may
not be defensible if a waste is misidentified by the generator and passes the fingerprint test. Though the
generator is responsible for properly identifying and classifying the waste, the TSDF will be held liable
by enforcement authorities if it violates its permit conditions and any other applicable regulations. The
decision to conduct abbreviated corroborative testing using fingerprint analysis on a few select parameters, or to conduct a complete analysis to verify the profile, is ultimately determined by the off-site
facility with this in mind.
2.6
Special Procedural Requirements
2.6.1
Procedures For Receiving Wastes Generated Off Site
Off-site hazardous waste management facilities are required to comply with additional regulations28
regarding screening and analysis procedures that help minimize the potential for the facility to accept
incorrectly identified or unacceptable waste shipments. The off-site facility's WAP must specify the
waste analysis data that the generator of the waste provides to substantiate its waste determination. It is
important that the WAP includes descriptions of the procedures to be taken by the TSDF to determine
how well the generator's data represents the wastes to be managed. The TSDF should determine
whether recharacterization of the waste is necessary if a shipment of a particular waste is determined,
through pre-acceptance screening, to be significantly different from the waste as characterized and
identified from the pre-shipment sample and/or waste manifest. These procedures and waste
recharacterization procedures should be specified in the WAP. Alternatively, the owner/operator may
reject the entire shipment of waste and return the waste to the generating facility.
An off-site facility should, at a minimum, visually inspect and compare the contents of each shipment to
the accompanying manifest to identify the wastes. The shipment received on site should be sampled
and analyzed to the extent necessary to verify that it meets permit specifications and regulatory requirements. Some off-site facilities accomplish this by performing a systematic process of screening and
analysis which allows for monitoring key indicator parameters. In some cases, however, more stringent
waste analysis may be required. Figure 2-11 provides a methodology that can be used to screen waste
shipments.
Shipment screening is especially necessary for off-site facilities given the variety of wastes typically
managed. The level of screening required for an off-site facility is a function of the facility operator's
knowledge about the generation process. Off-site facilities should require that the generator provide
detailed information regarding:
28
•
The process that generates the waste
•
The physical and chemical description of the waste
40 CFR §§264/265.13(c)
2-45
2-46
•
The analytical procedures and results used to characterize the waste or process knowledge
documentation
•
EPA hazardous waste codes
•
Certifications and notifications as applicable to LDR wastes.
As discussed in the previous section (Section 2.5), as a pre-acceptance procedure, most
commercial TSDFs will require that the generator provide all of this information in the form of a
Waste Profile Sheet. An example of a Waste Profile Sheet is provided in Table 2-11 located at the
end of Part Two.
Fingerprint analysis, including the application of associated analytical test methods, should be
performed during the pre-acceptance phase of waste management as a complement to information
gained from the generating facility. Typically, waste shipments are sampled and analyzed for a few
key chemical and physical parameters to substantiate the waste composition designated on the
accompanying shipping paper or manifest. This practice expedites waste characterization and minimizes the time and labor involved in shipment receiving activities. Key parameters are selected
from the initial waste characterization parameters measured before you agree to handle the
generator's wastes. When selecting fingerprint parameters, you should consider those parameters
that can be used to:
•
Identify wastes that are not permitted
•
Determine whether the wastes are within the management unit's operational acceptance limits
•
Identify the potential ignitability, reactivity, or incompatibility of the wastes (refer to
Section 2.2.1)
•
Indicate any changes in waste composition that may have occurred during transportation or
storage (e.g., a spent solvent used in paint thinning processes that has been documented to be free
of chlorine and fluorine should not exhibit high total halogen concentrations.)
Generally, at a minimum, at least two parameters should be selected for fingerprint analysis of
wastes prior to acceptance at an off-site TSDF. At least one parameter should be qualitative (e.g.,
color or phase) and the other should be quantitative (e.g., pH, specific gravity, flash point). Each
qualitative and quantitative parameter should have acceptance, rejection, and further testing criteria
associated with it.
While fingerprint parameters are often a subset of the full waste characterization parameters, this
may not always be the case. For example, one may use screening tests to detect constituents that are
not normally present in the waste, even though the initial waste profile does not identify the specific
contaminant. Most facilities, for example, will test or require information pertaining to PCB content
with each shipment.
Although key parameters can be used to obtain quickly a representation of waste composition,
owner/operators should be aware that EPA will generally measure compliance in enforcement
actions based on a comprehensive analysis of hazardous constituents and properties associated with
a particular waste. As a result, the selection of key parameters must be based on sufficient waste
profile knowledge and testing data to ensure accurate waste representation.
2-47
2.6.1.1 Re-Evaluation Of Wastes Received At Off-Site Combustion Facilities
Though fingerprint analysis and screening may be adequate for many TSDFs, additional information
may be required for off-site combustion facilities. In particular, the WAP must specify procedures that
ensure compliance with the site-specific waste feed restrictions. These restrictions are developed after
the trial burn, become part of the permit, and specify restrictions on operating conditions and waste
feed composition.
At a minimum, an off-site combustion facility must analyze the wastes it receives for prohibited constituents, (e.g., PCBs; dioxin-containing wastes; reactive wastes; and Part 261, Appendix VIII constituents not represented by the POHCs selected for the trial burn), thermal input, ash content, chloride,
total toxic metals, (e.g., antimony, arsenic, barium, beryllium, cadmium, chromium, lead, mercury,
nickel, selenium, silver, thallium, vanadium, and zinc), and other parameters as necessary (e.g., viscosity, percent solids, solids size, and specific gravity).
Each batch of waste to be burned must be analyzed. A typical scenario would include: receive
waste, conduct fingerprint analysis, blend wastes in feed or burn tank, and analyze the batch for the
above referenced constituents and parameters.
On-site facilities may use a lower frequency of analysis but the frequency must be based on a firm
statistical basis.
As noted in Section 2.5, though the generator is responsible for properly classifying the wastes,
enforcement authorities will hold the combustion facility responsible and liable for any permit or
other regulatory violation.
2.6.2
Procedures For Ignitable, Reactive, And Incompatible Wastes
WAPs must include provisions to ensure that waste management units meet the special requirements
for ignitable, reactive, and incompatible wastes.29 Incompatible wastes, if brought together, may
result in heat generation, toxic gas generation, and/or explosions. Therefore, a WAP must address
measures to identify potentially ignitable, reactive, and incompatible wastes. The information provided by the waste manifest and fingerprint testing can be supplemented with other testing to identify
incompatible wastes. Standard tests to identify ignitable wastes are contained in section 7.1 of SW846. Although EPA does not currently have an approved set of test procedures for reactivity, specialized methods contained in sections 7.3.3.2 and 7.3.4.2 of SW-846, respectively, have been developed
to determine if a cyanide or sulfide waste exhibits the reactivity characteristic. Additionally, reference
should be made to "Design and Development of a Hazardous Waste Reactivity Testing Protocol"
(EPA-600/52-84-057) for suggested reactivity fingerprint analysis procedures. Finally, waste compatibility determinations can serve to establish compatibility between wastes of interest for a given process. An EPA document, "A Method of Determining the Compatibility of Hazardous Wastes" (EPA600/2-80-076)30 , contains procedures to evaluate qualitatively the compatibility of various categories
of wastes.
29
30
40 CFR §§264/265.17
This document can be obtained from the National Technical Information Service (NTIS)
(Document No. PB-80221005).
2-48
2.6.3 Provisions For Complying With LDR Requirements
Generators and TSDFs have special waste analysis requirements under the LDR program. Regulations
in 40 CFR §268.7 require generators and TSDFs to conduct waste analysis to determine the regulatory
status of wastes with respect to the treatment standards in 40 CFR Part 268, Subpart D. Generally,
hazardous wastes must meet applicable treatment standards prior to land disposal. These treatment
standards are expressed in two ways: as constituent concentrations in the waste (either an extract of the
waste as determined by the TCLP, or in the total volume of the waste referred to as a total waste analysis) or as specified treatment technologies. Wastes with concentration-based treatment standards must
be evaluated to determine if applicable constituent concentration levels have been attained. This can be
accomplished by applying waste analysis procedures as either (l) testing the waste, or (2) using knowledge of the process or materials used to produce the waste (for generators only). For (2), this knowledge should be supplemented with analytical data on the regulated constituents.
For treatment standards expressed as concentrations in the waste extract (40 CFR §268.41 and
§268.46), the TCLP (EPA Method 1311 of SW-846) must be employed to obtain an extract of the
waste (there are certain exceptions where Method 1310, the Extraction Procedure Toxicity Test, can be
used as an alternative for those arsenic- and lead-containing waste codes listed in 40 CFR §268.40(a)).
The extract will be be tested subsequently for the specific constituents associated with the treatment
standard. Treatment standards based on total waste concentrations in 40 CFR §268.43 should be
verified using an appropriate total waste analysis procedure for its respective constituents. Please note
that many wastes have treatment standards expressed as both extract concentrations and total waste
concentrations.
For wastes with treatment standards expressed as specified technologies in 40 CFR §268.42, and for
hazardous debris treated to meet the alternative debris treatment standards in 40 CFR §268.45, verification through analysis is not necessary. Instead, compliance with these treatment standards should be
documented in the facility operating record to verify that the appropriate treatment technologies have
been employed prior to land disposal.
2.7
Summary
In Part Two, you have learned what information should be included in your WAP, and
how the information should be organized. In particular, you reviewed how to select:
•
Waste analysis parameters
•
Sampling procedures
•
Analytical and testing methods
•
Waste re-evaluation frequencies.
In addition, you learned about special procedural requirements (e.g., for off-site
TSDFs).
In Part Three, you will be presented with a checklist of key elements of a WAP. This checklist should
be reviewed while developing or modifying your WAP.
2-49
TABLE 2-11
Example Waste Profile Sheet *
1. WASTE PROFILE #:
EPA Facility ID #:
DO NOT LEAVE BLANK SPACES. PLEASE SUBMIT THIS FORM TYPE-WRITTEN.
I.
GENERATOR INFORMATION
2.
Generator Name:
3. EPA ID #:
4.
Mailing Address:
5.
Plant Address:
6.
Business Contact:
Phone #:
7.
Technical Contact:
Phone #:
The following information is required to comply with RCRA 40 CFR §§264/265.13 (O.A.C. 3745-65-13) General Waste Analysis.
II. GENERAL WASTE INFORMATION
8. Waste Material Name:
9.
10. Describe process that generates waste:
11. SIC Code:
12. Is your company the original generator of the waste? ❑ No
❑ Yes
If not, provide the name of the original generator:
13. If this waste is a still bottom, are you the original generator of the feed stock?
14. Rate of Generation:
❑ No
❑ Yes
Current accumulation: Drums
15. Check all types of containerization for which you request quotation.
55-Gallon Steel Drum (SC)
30-Gallon Steel Drum
85-Gallon Steel Drum (Without inside container)
85-Gallon Salvage Drum (With fiber or steel
drums inside)
Palletized small containers
Overall dimensions of material on pallet:
x
Dimensions of pallet only:
x
x
What are the small containers on the pallet?
III.
Generator Code:
(Optional)
Bulk
(Gal.)
55-Gallon Fiber Drum
5-Gallon Pail
Bulk (For bulk shipments, waste viscosity
must be < 5000 cps)
Other (Specify)
x
(High)
(High)
(1 qt. Bottles, 8 oz. Aerosol Cans, etc.)
WASTE STREAM CHEMICAL COMPOSITION**
16. COMPONENTS INCLUDING 40 CFR 261
CONCENTRATION
APPENDIX VII HAZARDOUS CONSTITUENTS RANGE (UNITS)
AVERAGE %
MUST TOTAL 100%
TLV (IF PUBLISHED)
ACGIH
OSHA
to
to
to
to
to
to
to
*
**
If applicable, this Waste Profile Sheet is a new revision of a previously submitted Waste Profile Sheet dated
Attach to this Form any additional information which must be known to treat, store, or dispose of the waste in accordance with RCRA §§264/265.13,
including but not limited to data developed under RCRA Part 261, Laboratory Analysis Technical Publications or Material Safety Data Sheets.
40 CFR 261 Appendix VIII constituents should be identified for combustion facilities, even if not present in high enough concentrations to significantly
contribute to the 100% composition.
2-50
WASTE PROFILE #:
VI. PHYSICAL PROPERTIES
IV. SPECIFIC ANALYSIS OF WASTE
17. Method used to obtain a representative sample of the
analyzed waste (i.e., grab, composite, etc.) Sampling
methods are described in RCRA 40 CFR 261 Appendix 1.
Generator’s Knowledge & MSDS
27. Is material pumpable? ❑ No
In completing the next two items, do not leave blanks. If the
specific element is not present, indicate “None”.
CONCENTRATION
18. Organic Bound
RANGE
26. Physical state at 70° F (Circle)
Liquid
Semisolid
Slurry
Sludge
Viscosity at 70° F
Solid
Gas
CPS
❑ Yes
Varies (Explain):
28. Is waste multi-layered? ❑ No ❑ Yes
If yes, please describe and quantify each layer:
AVERAGE
Sulfur
to
1. (Top)
%
Chlorine
to
2.
%
Fluorine
to
Bromine
to
29. Dissolved Solids:
% WT
Iodine
to
30. Suspended Solids:
% WT
Nitrogen
to
Phosphorus
3.
31. BTU Value/lbs:
to
32. Ash Content (% by WT):
(Base % WT on Molecular Structure)
34. Vapor Pressure at 70° F:
Arsenic
ppm
Mercury
ppm
Barium
ppm
Nickel
ppm
Cadmium
ppm
Selenium
ppm
36. pH:
Chromium
ppm
Silver
ppm
37. Corrosivity:
ppm
38. Color:
ppm
Thallium
°F
33. Flash Point:
19. Metals (Actual Content)
Lead
%
Aluminum
%
Silicon
%
Magnesium
%
Sodium
%
20. Does this waste contain PCBs?
❑ No ❑ Yes. If yes, give the concentration regardless of
amount and attach supporting documentation:
ppm
21. Does this waste contain insecticides, pesticides, herbicides, or
rodenticides?
35. Specific Gravity:
mpy
39. What is the Reactivity Group Number(s) for this waste?
In accordance with “Design and Development of Hazardous Waste Reactivity Testing Protocol, “EPA Document
No. EPA-600/2-84-057, February 1984.
40. Is this material stable?
❑ No
❑ Yes
If no, explain:
❑ No ❑ Yes. If yes, identify each in the space below and the
concentrations:
ppm
ppm
(Include Safety Data Sheets for each)
22. Does this waste contain Dioxin? ❑ No
41. Is this material shock sensitive?
❑ Yes
If yes, explain:
23. Does this waste contain free cyanide> 250 ppm?
❑ No ❑ Yes
24. Does this waste contain free sulfide > 250 ppm?
❑ No ❑ Yes
V. TOXICITY
25. Check Applicable Data
Eye
Explain
Inhalation
Explain
Dermal
Explain
Ingestion
Explain
Other
Explain
Carcinogen (suspected or known) Explain
2-51
❑ No
❑ Yes
WASTE PROFILE #:
VIII. EPA INFORMATION
43.
42. Is this waste hazardous as defined by RCRA 40 CFR Part 261? ❑ No ❑ Yes
If yes, list the applicable EPA Hazardous Waste Number(s) and explain why you
have assigned the number(s). For example, if you assign D001, the reason for
selection is that the flash point is less than 140° F. If you assign F002, the
reason for selection may be that the waste is the still bottom from the recovery
If the answer to #42 is yes,
list CERCLA reportable
quantities, found in 40
CFR §302.4:
of methylene chloride:
EPA Hazardous Waste Number(s)
44.
Reason for Selection
If the waste is not hazardous as defined by federal regulations but is hazardous as defined by state regulations in which the waste
was generated, please provide the state hazardous waste number(s). Also provide any state hazardous numbers that are not
included in the federal regulations:
State Hazardous Waste Number(s)
IX.
Reason for Selection
SAMPLING INFORMATION
45. Sample source (e.g., drum, lagoon, pond, tank, vat, etc.):
Date Sampled:
Sampler’s Name/Company:
47. ❑ No sample required (Provide rationale)
46. Generator’s Agent Supervising Sampling:
X.
LAND DISPOSAL RESTRICTIONS INFORMATION
48. Identify ALL characteristic and listed EPA hazardous waste numbers that apply (as defined by 40 CFR 261).
For eachwaste number, identify the subcategory (as applicable, check none, or write in the description from
40 CFR 268.41, 268.42, and 268.43).
REF
A. EPA
B. SUBCATEGORY
C. APPLICABLE TREATMENT
#
HAZARDOUS
ENTER THE SUBCATEGORY DESCRIPTION
STANDARDS
WASTE CODE(S)
IF NOT APPLICABLE
CHECK NONE
PERFORMANCEBASED
(CHECK AS
APPLICABLE)
DESCRIPTION
NONE
1
2
3
4
5
6
2-52
268.41(a) 268.43(a)
SPECIFIED
TECHNOLOGY IF
APPLICABLE
ENTER THE CFR
268.42 TABLE 1
TREATMENT
CODE(S)
268.42
D. HOW MUST
THE WASTE BE
MANAGED?
ENTER THE
APPROPRIATE
LETTER (A-D)
FROM BELOW
WASTE PROFILE #:
To list additional EPA waste numbers and categories, use additional page and check here: ________
Management under the land disposal restrictions:
A.
RESTRICTED WASTE REQUIRES TREATMENT?
❑ No
❑ Yes
B.1. RESTRICTED WASTE TREATED TO PERFORMANCE STANDARDS?
❑ NO
❑ Yes Method ____________
B.2. RESTRICTED WASTES FOR WHICH THE TREATMENT STANDARD IS EXPRESSED AS A SPECIFIED
TECHNOLOGY (AND THE WASTE HAS BEEN TREATED BY THAT TECHNOLOGY) ❑ NO ❑ Yes Method ____
B.3. GOOD FAITH ANALYTICAL CERTIFICATION FOR INCINERATED ORGANICS? ❑ NO
C. RESTRICTED WASTE SUBJECT TO A VARIANCE?
❑ No
❑ Yes
Date/Type ______________________
D. RESTRICTED WASTE CAN BE LAND DISPOSED WITHOUT FURTHER TREATMENT?
XI.
❑ Yes Method
❑ No
❑ Yes
DOT INFORMATION
In accordance with the Department of Transportation 49 CFR Parts 171 through 177, complete the following:
49. DOT Proper Shipping Name:
50. DOT Hazard Class:
51. DOT UN or NA Number:
52. Container Label(s):
(For containers of 110 gallons or less)
Additional Description
53. Placards:
Generator’s hazardous waste shipments must also comply with the labeling requirements of RCRA 40 CFR Part 262.
54. Is this waste a soil and/or debris?
No: ___
Yes, Soil: ___
55. COMPLETE ONLY FOR WASTES INTENDED
FOR FUELS OR INCINERATION
Yes, Debris: ___
56. RECLAMATION, FUELS OR INCINERATION PARAMETERS (Provide if information is available)
TOTAL
Antimony as Sb
Yes, Both: ___
RANGE
______________________________ ppm
A. Heat Value (BTU/lb.) _________ __________
Beryllium as Be ________________________________ ppm
B. Water: ______________________________
Potassium as K ________________________________ ppm
C. Viscosity (cps): ____________@_____°F ____100°F
______150°F
Sodium as Na
________________________________ ppm
Bromine as Br
________________________________ *ppm/%
Chlorine as Cl
________________________________ *ppm/%
Fluorine as F
________________________________ *ppm/%
Sulfur as S
________________________________ *ppm/%
D. Ash: ______________%
E. Settleable solids: _______________%
F. Vapor Pressure @ STP (mm/Hg): _______________
G. Is this waste a pumpable liquid?
❑ No
❑ Yes
H. Can this waste be heated to improve flow? ❑ No ❑ Yes
* Indicate ppm or %.
I. Is this waste soluble in water?
❑ No
❑ Yes
J. Particle size: Will the solid portion of this waste pass
through a 1/8-inch screen:
❑ No ❑ Yes
57. Special Handling Information
2-53
:
WASTE PROFILE #
ACCOUNTABILITY STATEMENT
58. I hereby certify that all information submitted in this and all attached documents contains true and accurate descriptions
of this waste. Any sample submitted is representative as defined in 40 CFR 261 Appendix I or by using an equivalent
method. All relevant information regarding known or suspected hazards in the possession of the generator has been
disclosed. I authorize (_____) to obtain a sample from any waste shipment for purposes of recertification.
Authorized Signature
Printed (or typed) Name and Title
Proceed to Part Three
2-54
Date
PART THREE:
CHECKLIST
Yes
1. Facility Description
a. Are all processes that generate hazardous
waste identified?
b. Is sufficient information provided for each
process to confirm that all hazardous wastes
are identified?
c. Have all hazardous waste management units
been identified?
d. Are descriptions of all hazardous waste
management units provided?
e. Have all hazardous and solid wastes been
identified for each unit?
f.
Have the methods of waste management
(e.g., stabilization) been described for each
unit?
g. Are process design limitations defined for
each hazardous waste management unit?
h. Have operational acceptance limits been
established for each hazardous waste
management unit?
i.
Are procedures in place to determine
whether wastes are outside of their
respective acceptance ranges?
j.
Do operational acceptance limits include
applicable regulatory restrictions?
2. Selecting Waste Parameters
a. Are parameters for waste analysis identified
(and, if applicable, included in the WAP)?
b. Does the WAP identify a rationale for the
selection of each waste analysis parameter?
c. Does the WAP include parameters for the
special waste analysis requirements in 40
CFR §§264/265.17, 264/265.314, 264/
265.341, 264/265.1034(d), and 266.102(b), if
applicable?
3-1
No
Comments
Part Three (continued)
Checklist
Yes
d. Have operational acceptance limits been
defined as they relate to waste properties
and process?
e. Do operational acceptance limits include
regulatory restrictions?
f.
Do waste analysis parameters address
applicable operational acceptance limits?
3. Selecting Sampling Procedures
a. Has the number of sampling locations been
identified?
b. Are sampling procedures for each waste type
identified?
c. Are descriptions and justifications provided
for any modified or non-standard procedures,
as approved by EPA?
d. Have decontamination procedures for
sampling equipment been developed?
e. Have sampling strategy techniques (e.g.,
grab, composite) been specified?
f.
Are procedures for sampling multi-phase
wastes (if applicable) addressed?
g. Has all sampling equipment been identified?
h. Have the number and types of sampling
containers been specified?
i.
Have sample preservation techniques been
specified?
j.
Are sampling quality assurance and quality
control procedures identified?
k. Are proper packing and shipping procedures
documented?
l.
Have procedures for the maintenance of all
sampling equipment been documented?
m. Are the precision and accuracy of sampling
equipment stipulated?
n. Are health and safety procedures for the
protection of sampling personnel specified?
3-2
No
Comments
Part Three (continued)
Checklist
Yes
4. Selecting A Laboratory And Laboratory
Testing And Analytical Methods
a. Are laboratory and analytical methods
specified for each waste managed at the
facility? If not, is other information (i.e.,
acceptable knowledge) used to demonstrate
waste analysis?
b. Has a rationale been specified for each
analytical and test method?
c. Do the selected analytical methods meet all
regulatory requirements for the identification
of each hazardous waste (e.g., each
hazardous waste characteristic)?
d. Are descriptions and justifications provided
for any modified or non-standard methods,
as approved by EPA?
e. Have chain-of-custody procedures for
samples been specified (if necessary)?
f.
Does the laboratory have an adequate QA/
QC program?
g. Have QA/QC procedures for each analytical
procedure been identified?
5. Selecting Waste Re-Evaluation Frequencies
a. Have site-specific criteria for waste reevaluations been specified?
b. Is re-evaluation accomplished with adequate
frequency?
c. Are mechanisms in place for re-evaluating
the sampling program each time the wastegenerating processes change?
d. Do the re-evaluation procedures specify
criteria for the acceptance of wastes received
from off-site generators?
e. Do you notify off-site facilities (i.e., treatment,
storage, and/or disposal facilities) of changes
in waste characterizations due to process
changes or other factors?
3-3
No
Comments
Part Three (continued)
Checklist
Yes
No
Comments
6. Special Procedural Requirements, Where
Applicable
a. Are procedures in place to verify the sources
of the information provided from off-site
generators or TSDFs (if applicable)?
b. Have criteria been established for the
preacceptance procedures of wastes based
on information from off-site generators or
TSDFs?
c. Are procedures for waste inspections in
place?
d. Have fingerprint analysis parameters been
developed?
e. Have criteria been established for the
acceptance of wastes based on the results of
fingerprint analysis?
f.
Is there a methodology for identifying
ignitable, incompatible, or reactive wastes?
g. Are procedures in place to conduct testing to
determine whether wastes are incompatible
with each hazardous waste management unit
on site?
h. Have all wastes restricted under the LDRs
been identified?
i.
Are procedures in place to ensure that
wastes meet applicable LDR treatment
standards prior to land disposal?
Proceed to Part Three
3-4
Introduction to Sample WAPs
PART FOUR:
SAMPLE WAPs
In Part Four, you will review five abbreviated sample WAPs that have
been developed to illustrate the following:
•
Suggested outlines for WAPs representing five different types of facilities
•
The content and level of detail recommended in a complete WAP.
The sample WAPs were developed in accordance with the guidance provided in
Parts One, Two, and Three of this manual.
4.0
Introduction To Sample WAPs
Part Four contains five abbreviated sample WAPs that you should use as guidance when developing your
facility’s WAP. You should consult Table 4-1 to determine the most appropriate sample WAP to use in
developing your facility’s WAP. However, regardless of which sample WAP you review, you should
first review Sample WAP #1 because it provides the background data and information used in
Sample WAPs #2, #3, #4, and #5.
The sample WAPs illustrate the recommended format and present excerpts of sample text for all key
sections. Excerpts of sample text are highlighted using italicized and indented text, and all figures
and tables are located at the end of each respective sample WAP. Unlike these sample WAPs, the
WAP you develop for your facility should provide more narrative discussions and graphical presentations
of relevant waste analysis considerations.
The sample WAPs address five waste management scenarios. These five scenarios are:
•
Generator only (i.e., no treatment)
•
Generator treating to meet LDR treatment standards
•
On-site treatment facility
•
Off-site treatment facility
•
Landfill.
Each scenario depicts the fate of one or more of the hazardous wastes (HW) that are generated from the
manufacturing processes of a fictitious generator and TSDF called Thompson Manufacturing, Inc. Two
other fictitious TSDFs — Sparky Incinerator, Inc., and Rottaway Landfill, Inc. — are used for treatment
and land disposal of Thompson’s wastes. Detailed information on each of the five waste management
scenarios used to develop the sample WAPs is provided in Tables 4-2 through 4-6.
[Note: A WAP for generators who are NOT engaged in any treatment activities is included
as Sample WAP #1; however, as stated previously in this manual, these facilities are encouraged but not required to develop a WAP.]
4-1
Introduction to Sample WAPs
TABLE 4-1
Guide To The Sample WAPs
IF YOU ARE A …
SEE SAMPLE
WAP #:
SYNOPSIS OF SCENARIO
Generator, and you …
- Send all hazardous
wastes generated to an
off-site TSDF and/or
send wastewaters to a
POTW.
1
- Treat in tanks,
containers, and/or
containment buildings to
meet LDR treatment
standards. Neutralized
wastes are discharged
to an on-site wastewater
storage tank (non-RCRA
regulated).
1 and 2
- Generator Only Thompson is a generator, pursuant
to 40 CFR Part 262, that sends all
of its hazardous wastes off site for
treatment and or disposal at
commercial TSDFs.
- Generator Treating to Meet
LDR Treatment Standards Thompson continues to be a
generator in accordance with
Scenario 1, but the company
elects to treat acid wastes on site
in tanks to meet LDR treatment
standards, pursuant to 40 CFR
§268.7.
Generator and/or TSDF, and
you …
- Treat hazardous wastes
on site.
1 and 3
- On-Site Treatment Facility In addition to treating in tanks and
containers (per Scenario 2,
above), Thompson receives a
permit to treat metal-containing
wastes in an on-site stabilization
unit.
- Own or operate
treatment unit or units
that receive(s)
hazardous wastes from
off site.
1 and 4
Own or operate a landfill
- that receives hazardous
wastes that are
generated on site or off
site.
1 and 5
- Off-Site Treatment Facility All solvent-bearing hazardous
wastes generated at Thompson
are sent to Sparky Incineration,
Inc.
- Landfill Rottaway Landfill, Inc. operates as
a TSDF that accepts stabilized
hazardous wastes from Thompson
and ash from Sparky.
4-2
Introduction to Sample WAPs
TABLE 4-2
Scenario Overview Sample WAP #1
—Generator Only—
Thompson Manufacturing, Inc., is a semiconductor manufacturing facility that sends all of the
hazardous wastes it generates to an off-site TSDF for treatment and/or disposal. The scenario
depicted in Sample WAP #1 is shown below.
Process/Activity
Generating HW
Parts Preparation
- Electroplating
- Parts Drying
- Machining
Painting
- Cleanup
Wastes Generated
EPA Waste
Code
LDR
NWW or WW1
Treatment/Disposal Method
and Location
Wastewater Treatment Sludge
F006
NWW
Solvents
F002
NWW
Sent off site to Solid
Stabilization, Inc.*
Sent off site to Sparky
Incineration, Inc.
Cutting Oils, Metal Shavings
and Scraps
N/A
N/A
F003
NWW
Solvents
- Waste Paint
Waste Paint Residues
D008
D009
NWW
NWW
Clean Room
- Glass Etching
Hydrofluoric Acid (HF)
D002
WW
-1 NWW- Nonwastewater; WW - Wastewater
Sent off site to a reclaimer *
Sent off site Sparky
Incineration, Inc.
Sent off site to Solid
Stabilization, Inc.*
Sent off site to Corrosive
Neutralizes, Inc.*
* These facilities are not addressed in the
sample WAPs (i.e., not applicable)
TABLE 4-3
Scenario Overview Sample WAP #2
—Generator Treating To Meet LDR Treatment Standards—
Thompson elects to conduct on-site treatment of the acid wastes (D002) generated in the clean room.
This treatment occurs in tanks for the purpose of meeting LDR treatment standards. All other wastes
generated at Thompson continue to be sent to off-site TSDFs (see Sample WAP #1). The scenario
depicted in Sample WAP #2 is shown below.
Process/Activity
Generating HW
Wastes
Generated
EPA Waste
Code
Hydrofluoric
Acid (HF)
D002
LDR
NWW or WW
Treatment/Disposal Method
and Location
Clean Room
- Acid Etching
WW
4-3
On-Site Treatment in Tanks
(Neutralization)
Introduction to Sample WAPs
TABLE 4-4
Scenario Overview Sample WAP #3
—On-Site Treatment Facility—
In addition to treating acid wastes to meet LDR treatment standards (see Sample WAP #2), Thompson elects to conduct on-site treatment, using stabilization, of the electroplating wastewater treatment
sludges (F006) and waste paint residues (D008 and D009). All other hazardous wastes continue to
be sent off site to a commercial TSDF (see Sample WAP #1) or treated on site in tanks (see Sample
#2). The scenario depicted in Sample WAP #3 is shown below.
Process/Activity
Generating HW
Wastes
Generated
EPA Waste
Code
LDR
NWW or WW
LDR Treatment
Standard
Sludge
F006
NWW
See Scenario Overview
Sample WAP #5
Waste Paint
Residues
D008,
D009
NWW
Pb 5 mg/l
Hg 0.2 mg/l
Electroplating
- Wastewater Treatment
Painting
- Parts Cleanup
TABLE 4-5
Scenario Overview Sample WAP #4
—Off-Site Treatment Facility—
Thompson has always sent its solvent wastes, generated in the electroplating and painting processes,
off site to Sparky Incineration, Inc. (see Sample WAP #1). For this fourth scenario, we have chosen
to go to Sparky Incineration, Inc., and develop a sample WAP for the wastes that Sparky receives
from Thompson. (All other hazardous wastes generated at Thompson continued to be managed in
accordance with Sample WAPs #2 and #3.) The scenario depicted in Sample WAP #4, which
addresses the incineration activities at Sparky Incineration, Inc., is shown below.
Name of Generator/
EPA ID No.
Thompson
Manufacturing, Inc.
EPA ID No.
GFA068291377
Process/Activity that
Generates Wastes
Parts Preparation
- Parts Drying
Painting
- Parts Cleanup
Waste
Description
EPA Waste
Code
LDR
NWW or WW
LDR
Treatment
Standard
(mg/kg)
Solvents
(trichlorofluoromethane,
CFC-11)
F002
NWW
33
Solvents
(Acetone)
F003
NWW
160
4-4
Introduction to Sample WAPs
TABLE 4-6
Scenario Overview WAP #5
—Landfill—
All of the wastes that are generated at Thompson Manufacturing, Inc., are ultimately disposed of
in the Rottaway Landfill. This landfill, therefore, receives incinerated waste residues from
Sparky Incineration, Inc., and it receives stabilized wastes from Thompson Manufacturing, Inc.
The scenario depicted in Sample WAP #5, which addresses the landfilling of waste at Rottaway,
is shown below.
Name of Generator/
EPA ID No.
Thompson
Manufacturing, Inc.,
EPA ID No.
GFA068291377
Sparky Incineration,
Inc.,
EPA ID No.
SIT043377911
1
Process/Activity
Generating HW
Waste
Description
EPA Waste
Code
LDR
NWW or
WW
LDR Treatment
Standard1
Stabilization
Treated Solids
From
Electroplating
Wastewater
Treatment
F006
NWW
Cd 0.066
Cr 5.2
Pb 0.51
Ni 0.32
Ag 0.072
CN (total)
590 mg/kg
CN (amenable)
30 mg/kg
Stabilization
Treated Paint
Solids
D008,
D009
NWW
NWW
Neutralization
Sludge
N/A
Residues From
Tank Treatment
Incinerated Waste
Solvents From Painting
Process, Originally
Generated at Thompson
One of Many
Wastes
Contributing to
Incineration
Slag
F003
NWW
acetone
160 mg/kg
Incinerated Waste
Electroplating Solvents
Originally Generated at
Thompson
One of Many
Wastes
Contributing to
Incineration
Slag
F002
(trichlorofluoromethane,
CFC-11)
NWW
trichlorofluoromethane
33 mg/kg
Pb 5
Hg 0.2
The LDR treatment standards for metals are for the constituent concentrations in the TCLP extract in mg/l. For
all other constituents the standards are the concentrations in the total waste analysis in mg/kg.
4-5
Introduction to Sample WAPs
Each sample WAP generally follows the format discussed in Part Two of this guidance
manual; therefore, each has six sections. However, you may choose to arrange the sections in
any order that works best for your facility. For example, you will note that Sample WAPs #4
and #5 have been rearranged slightly due to facility-specific circumstances (e.g., receiving
wastes from off site). The model outline generally used in the sample WAPs is provided below.
TABLE 4-7
Model Outline Of Sample WAPs
I.
Facility Description
A.
B.
C.
Description of Facility Processes and Activities
Identification/EPA Classification and Quantities of Hazardous Wastes Managed
Description of Hazardous Waste Management Units
II. Selecting Waste Analysis Parameters
A.
B.
Criteria and Rationale for Parameter Selection
Special Parameter Selection Requirements
III. Selecting Sampling Procedures
A.
B.
C.
D.
Sampling Strategies and Equipment
Sampling Preservation and Storage
Sampling QA/QC Procedures
Health and Safety Protocols
IV. Selecting a Laboratory, and Laboratory Testing and Analytical Methods
A.
B.
Selecting a Laboratory
Selecting Testing and Analytical Methods
V. Selecting Waste Re-Evaluation Frequencies
VI. Special Procedural Requirements
A.
B.
C.
Procedures for Receiving Wastes From Off-Site Generators
Procedures for Ignitable, Reactive, and Incompatible Wastes
Procedures To Ensure Compliance With LDR Requirements
[Note: Figures and tables can be found after the text portion of each respective sample WAP.]
4-6
Sample WAP # 1 - Generator Only
SAMPLE WAP #1 — GENERATOR ONLY
[Note: This is an example of what a generator’s WAP would look like if a generator regulated under 40
CFR Part 262 elected to develop a WAP. As noted in Parts One and Two of this guidance manual, generators do not have a regulatory obligation to develop a WAP unless the generator is also involved in an
activity for the treatment, storage, or disposal of hazardous waste regulated under 40 CFR Parts 264, 265,
or 268 (i.e., 40 CFR §268.7). In addition, this sample WAP provides background data and information
used in Sample WAPs #s 2, 3, 4, and 5.]
I.
FACILITY DESCRIPTION
As discussed in Section 2.1 of this manual, the Facility Description section of your WAP should address
the following areas:
•
Description of the processes and activities used to generate or manage the wastes
•
Identification/classification and quantities of hazardous wastes generated and managed
•
Description of the hazardous wastes management units.
Each of these areas is discussed below.
A.
Description Of Facility Processes And Activities
The overview of the facility processes should include a description of the types of products that are manufactured and the processes used to manufacture the products. A facility layout and a schematic showing
the relationship between the operations and hazardous wastes that are generated should be included along
with the narrative description. For example:
Thompson Manufacturing, Inc., is a semiconductor manufacturing company that
produces small glass and metal electronic components used to make various models of
toy dolls and trucks. There are three processes that generate wastes, as follows:
•
•
•
Operation A: Clean Room Operations
Operation B: Parts Preparation
Operating C: Painting.
These three processes and the solid and hazardous wastes that they generate are
illustrated in Figure 4-1, and described below:
Operation A: Clean Room Operations involve processing small glass parts by
etching these parts with hydrofluoric acid (HF) jet guns, making indentations and
holes in the parts in accordance with the manufacturing design criteria.
Operation B: Parts Preparation involves three activities: (1) electroplating chromium onto nickel parts, (2) machining the parts into desired shapes and lengths, and
(3) parts drying. Electroplating involves taking small nickel metal parts and dipping
them in acid solutions containing chromium and running an electric current through
the solution, thereby allowing the chromium to become plated onto the nickel parts.
Electroplating generates waste acids that are sent to the wastewater treatment
facility that discharges
4-7
Sample WAP # 1 - Generator Only
under an NPDES permit. The parts are removed from the plating baths and
sent to parts cutting. The parts are cut into desired shapes and lengths using
lathes and other heavy machinery. Machining activities generate waste
cutting oils. Finally, the metal parts are dryed by dipping the parts into
solvent baths and allowing the parts to dry in the air drying chambers. Parts
drying activities generate waste solvents.
Operation C: Painting involves the formulation of various grade paints for
industrial applications. The paint is a water reducible paint containing 5%
organics. Off-specification paints and sludge process residues are removed
daily and placed into dedicated waste drums. Piping and paint mixing basins
associated with the process are cleaned weekly with acetone.
A detailed facility engineering drawing of these processes is provided [Note:
A facility drawing is not included in this sample WAP.]
In addition, the WAP should include, a brief description of the waste handling activities that occur on
site. For example:
Wastewaters are piped directly to the on-site wastewater treatment facility
which discharges under an NPDES permit. The other wastes are collected
from operations A, B, and C in 55-gallon accumulation drums located in the
process area. The drums are prelabeled so that operators will place the wastes
in the correct drum. Each day these drums are collected and transferred to the
temporary container storage area where wastes are staged prior to shipment
off site. Upon receipt at the container storage area, a random number of
drums are inspected against the waste profile data that has been developed for
each wastestream to see if the waste appears to match the description on the
waste profile sheet. A sample of this waste profile sheet was provided in Table
2-11.
B.
Identification/EPA Classification And Quantities Of Hazardous Wastes Generated
Wastes that are generated at Thompson Manufacturing, Inc., should be described in detail in this
section. We have provided a sample list in Table 4-8. A narrative discussion of each column should
accompany this type of table. For example, the discussion of chemical analysis (column 7) and
applicable LDR treatment standard (column 8) might read as follows:
Laboratory analysis has indicated that the concentration of many constituents of the waste
(e.g., trichlorofluoromethane, CN, Cd, Cr, Pb, Ni, acetone, Hg, and Pb) as provided in
column 7 of Table 4-8 exceed LDR treatment standards provided in column 8. Consequently,
these wastes will be sent off site, with appropriate LDR notification, for treatment and disposal.
C.
Description Of Hazardous Waste Management Units
Because Thompson Manufacturing, Inc., is strictly a generator pursuant to 40 CFR Part 262, there are
no permitted hazardous waste management units at this facility.
You should, however, briefly describe the wastewater treatment plant, and the sludge press, including
its waste feed locations and sludge output locations. For example, you might address whether:
•
The sludge is collected in a hopper
4-8
Sample WAP # 1 - Generator Only
•
•
The sludge hopper is protected from precipitation
Procedures are in place to ensure that the wastes will be shipped off site within
90 days.
Because wastes are temporarily stored prior to being sent off site to a TSDF, you should also include
a description of the physical and chemical properties of the drum storage area and drum storage
arrangements so that compatibility considerations necessary for safe storage can be adequately
addressed. In addition, you should discuss the procedures for receiving wastes at the drum storage
area. For example, the following information might be included:
The temporary drum storage capabilities for Thompson Manufacturing are limited by the
amount of space available for holding drums and the spill containment capacity of the area.
Approximately twenty, 55-gallon drums may be maintained on site in the storage area at any
given time, in one of the three containment areas. The storage pad consists of a lined concrete slab with three spill containment areas of 60 gallons each (more than 10 percent of the
total capacity of the seven drums that can be stored in each area, but equal to the capacity of
one drum). One compartment shall be used exclusively for waste hydrofluoric acid (D002),
another for electroplating wastewater treatment sludges (F006), and the remaining compartment for the solvent (F002, F003) and waste paint residues (D008, D009). The storage area
is sheltered and maintained at 60 degrees Fahrenheit to minimize waste storage problems
associated with climatic variations. Daily inspections of the storage area are conducted to
ensure that container integrity is maintained.
The 55-gallon drums are used to contain the hazardous wastes generated from Thompson
Manufacturing’s clean room, parts preparation, and painting operations. For each respective operation, Department of Transportation (DOT) specification drums were selected based
on the physical and chemical properties of the wastes to be managed. Specifically, DOT
specification 17E closed head and DOT specification 17C open head drums are used to store
liquid (solvents, corrosives) and solid (F006, toxic paint sludges) wastestreams, respectively.
For noncorrosive wastestreams, including toxic metals and solvents, metal drums are used
for temporary waste accumulation. Conversely, acid wastes generated from glass etching
and electroplating are stored in polyethylene drums to minimize risks of rupture or leakage.
Incompatible wastes will be separated by a containment wall to prevent mixing if drums leak
or break.
II.
SELECTING WASTE ANALYSIS PARAMETERS
As discussed in Section 2.2 of this manual, this section of your WAP should address the following
areas:
•
•
A.
Criteria and rationale for parameter selection
Special parameter selection requirements.
Criteria And Rationale For Parameter Selection
Generally, waste parameters are selected based on three categories:
•
•
•
Waste identification
Identification of incompatible/inappropriate wastes
Process and design considerations.
4-9
Sample WAP # 1 - Generator Only
An example of what information can be provided in this section includes:
Since our facility’s operating constraints are only physical (the amount of available waste
storage and spill containment capacity), the waste analysis parameters that must be measured are those associated with confirming the identification/classification and compatibility
of the wastes.
To facilitate waste identification and parameter selection, we have reviewed 40 CFR 261,
Appendix VII - Basis for Listing Hazardous Wastes (i.e., F002, F003, F006, D002, D008,
and D009) — for the hazardous wastes generated by Thompson Manufacturing. The results
of this evaluation were cross-referenced with chemical analyses of the wastes performed by
an independent laboratory (Buchanan Laboratory) to identify our wastes and the parameters, and the associated rationale, necessary to ensure proper waste management.
Based on our in-depth knowledge of the raw materials and physical/chemical processes of
each of Thompson Manufacturing’s activities, as well as analytical results, the parameters
that were selected to confirm accurate waste identification (including those identified in the
40 CFR Part 261 Appendix VIII, hazardous constituents) for each hazardous waste are
illustrated in column 7 of Table 4-8. (Table 4-9 presents the rationale for select parameters.)
To ensure complete characterization of listed wastes for compliance with the LDR regulations, knowledge of the process, and where necessary, testing has been used to determine if
the hazardous wastes exhibit any of the four characteristics (i.e., ignitability, corrosivity,
reactivity, and toxicity characteristic (TC)). Results of these characteristic determinations
also provide the necessary information to verify that appropriate compatibilities are maintained during waste storage.
The wastes generated by Thompson Manufacturing must be amenable to safe storage in 55gallon drums for up to 90 days. The wastes we generate meet this criterion because:
1) the storage drums were selected to be compatible with each respective wastestream that
we generated, and 2) our manufacturing processes yield wastestreams that exhibit minimal
variability in composition.
B.
Special Parameter Selection Requirements
This section of your WAP should include any sampling, analytical, and procedural methods that will
be used to comply with specialized waste management requirements established for waste management units. For example:
As stated previously under the facility description portion of this WAP, each type of
wastestream (e.g., corrosive, spent solvent) will only be accumulated with wastes of identical
process origin. However, since incompatibilities may arise from mixing corrosives with
cyanide-bearing F006 wastes, separate color-coded waste drums will be used as a precautionary measure to ensure that corrosives are isolated. In addition, a short-turn-around-time
cyanide test (see sample analysis testing procedures below) will be performed for each batch
of F006 waste to be transferred to the on-site storage area. Any F006 waste exhibiting a
cyanide concentration of greater than 150 mg/kg will be stored in a special isolated area
until off-site shipment can be arranged. This additional safety measure will minimize the
4-10
Sample WAP # 1 - Generator Only
III.
SELECTING SAMPLING PROCEDURES
As discussed in Section 2.2 of this manual, this section of your WAP should address the following
areas:
•
•
•
•
A.
Sampling strategies and equipment
Sample preservation and storage
Sampling QA/QC procedures
Health and Safety Protocols.
Sampling Strategies And Equipment
This section should discuss how you will obtain a representative sample of each wastestream, including the sampling strategy and sampling equipment. For example:
We sample one drum per wastestream from each process area since: 1) we generate relatively small volumes of waste, and 2) the waste has a very low potential for varying in composition within each process area, as verified through historical analysis. Specific waste
sampling methods, equipment, and sample handling procedures to be used for each
of Thompson Manufacturing’s wastes are illustrated in Table 4-10.
B.
Sample Preservation And Storage
This section should discuss the sampling preservation, if applicable, and storage techniques you will
use to ensure the integrity of the sample. Site-specific sample language for the sampling preservation and storage requirements, however, are not provided in Sample WAP #1 because this information was covered extensively in Section 2.3.
C.
Sampling QA/QC Procedures
This section should include a description of the process used to ensure that all data collected is of
high quality. For example:
All sampling conducted for the purpose of characterizing wastes generated by Thompson
Manufacturing will use appropriate QA/QC procedures, including chain-of-custody from
sample collection through delivery to the analytical laboratory, and compatible storage
containers. Additionally, Thompson Manufacturing will limit the number of personnel who
perform sampling to two individuals to ensure the highest levels of consistency and accuracy.
Both individuals receive annual training in the proper use of sampling and analysis equipment identified in Table 4-10 and Table 4-11.
D.
Health And Safety Protocols
This section is not required to be included in a WAP but is included in Sample WAP #1 to emphasize that because the WAP may function as a stand-alone document, all information pertaining to
health and safety protocols and procedures appropriate to WAP activities should be included. For
example:
During all sampling activities, precautions will be taken to ensure that drums do not expel
gases and/or pressurized liquids. All personnel will be properly trained in safety and
handling techniques.
Subsequent sample APs will not include a Health and Safety Protocols section.
4-11
Sample WAP # 1 - Generator Only
IV.
SELECTING A LABORATORY, AND LABORATORY TESTING AND
ANALYTICAL METHODS
As discussed in Section 2.2 of this manual, this section should address how you will:
•
•
A.
Select an analytical laboratory
Select testing and analytical methods.
Selecting A Laboratory
This section should discuss the criteria you have used to select a laboratory (see Section 2.4.1 of this
manual). For example:
We have selected Buchanan Laboratory to perform all of the detailed quantitative chemical
analyses specified in our WAP. In particular, this laboratory has:
•
•
•
B.
A comprehensive QA/QC program
Technical analytical expertise
An effective information system.
Selecting Testing And Analytical Methods
This section should discuss how reliable analytical testing data is going to be obtained. For example:
The selection of analytical testing methods for the wastestreams generated by Thompson
Manufacturing was based on the following four considerations:
•
•
•
•
Physical state of the waste (e.g., viscous sludge)
Analytes of interest (e.g., acetone)
Required detection limits (e.g., regulatory thresholds)
Information requirements (e.g., verify compliance with LDR treatment standards,
waste classification).
Collectively, these factors contributed to the selection of the analytical procedures designated in Table 4-11. In the event that Thompson becomes subject to new regulatory requirements, additional testing methodologies will be incorporated into Table 4-11 as appropriate.
V.
SELECTING WASTE RE-EVALUATION FREQUENCIES
As discussed in Section 2.5 of this manual, this section should discuss how you will ensure that your
data are accurate and up-to-date. For example:
In accordance with the requirements of the off-site TSDFs used to treat and/or dispose of
our hazardous wastes, semi-annual samples will be taken from each process at Thompson
4-12
Sample WAP # 1 - Generator Only
Manufacturing for the purposes of conducting comprehensive physical and chemical analyses.
This information will be used to determine the appropriateness of current waste handling, storage, and characterization regimes. Specifically, these wastes will be subjected to the appropriate
tests (several of these are specified in Table 4-11).
VI.
SPECIAL PROCEDURAL REQUIREMENTS
As discussed in Section 2.6 of this manual, this section should address:
•
•
•
A.
Procedures for receiving wastes from off-site generators
Procedures for ignitable, reactive, and incompatible wastes
Procedures to ensure compliance with LDR requirements.
Procedures For Receiving Wastes From Off-Site Generators
Ordinarily, this section should describe waste acceptance procedures. However, since Thompson Manufacturing does not receive wastes from off-site generators, no additional procedures are applicable to the
receipt of off-site wastes.
B.
Procedures For Ignitable, Reactive, And Incompatible Wastes
This section should address procedures that ensure safe management of wastes. For example:
Thompson Manufacturing has instituted a rigorous analytical program to provide information
concerning a waste’s ignitability, reactivity, or incompatibility prior to treatment. Specifically,
wastes are evaluated against applicable hazardous waste characteristics to determine the presence of potentially ignitable, reactive, or incompatible wastes that may damage the treatment
process and/or associated facilities/personnel. Ignitability data will be obtained by using process
knowledge and the appropriate Setaflash open or closed cup apparatus for the given liquid hazardous waste. Potential reactivity characteristics will be assessed through the use of process
knowledge and, for cyanide containing wastes, by applying EPA SW-846 Method 7.3.3.2 to
determine the amount of free cyanides released when the waste is exposed to pH conditions of 2.0.
Any wastes identified as having a potential to liberate greater than 150 mg/kg of cyanide will be
segregated from all other wastes and stored in a specially bermed drum storage cell.
In addition to determining whether wastes designated for treatment exhibit hazardous characteristics, such as ignitability and reactivity, wastes may be subject to a compatibility evaluation.
This evaluation uses the procedures delineated in the EPA document entitled “Design and Development of a Hazardous Waste Reactivity Testing Protocol,” February 1984, EPA 600/2-84-057.
These test procedures are used to classify wastes based on gross chemical composition for designation according to specific reactivity groups. A flowchart representing the procedures to classify the waste as acid, base, oxidizing, reducing, reactive, and primarily organic or inorganic is
shown in Figure 4-2.
The results of the testing procedures yield reactivity group designations (See Figure 4-3). These
designations are subsequently used in the compatibility matrix in Figure 4-3 to determine the
potential effects of mixing the waste with wastes of other reactivity groupings likely to be encountered. In cases where incompatibility is indicated (or compatibility cannot be proven), the waste
will be handled as incompatible and will be ineligible for common storage. We will maintain this
type of information for each wastestream generated.
4-13
Sample WAP # 1 - Generator Only
C.
Procedures To Ensure Compliance With LDR Requirements
This section should discuss the applicable LDR requirements and how these requirements will be
satisfied. For example:
Solid wastes may require off-site treatment if they are determined to be listed wastes (e.g.,
F006) or if they exhibit hazardous characteristics. In accordance with the LDR regulations
(40 CFR Part 268), wastes shipped off site may need to be analyzed to determine whether the
waste meets the applicable LDR treatment standards contained in 40 CFR Part 268, Subpart
D. Testing will be conducted only to certify that the waste meets LDR treatment standards.
If it is known that the wastes do not meet applicable LDR treatment standards based on
process knowledge, no testing is necessary. Each waste for which a treatment standard has
been set will be evaluated for the applicable parameters in 40 CFR Part 268, Subpart D. All
analytical results completed in support of LDR requirements will be retained within the
facility operating record.
Wastes resulting from facility operations that exceed applicable LDR treatment standards
will be sent off site to a permitted treatment facility. LDR notifications will be supplied with
the shipment of waste with the information required under 40 CFR §268.7. In addition to the
LDR notification, any additional data for the wastestream (e.g., Waste Profile Sheet, analytical data) will be provided to the designated treatment facility.
All wastes, if any, that are determined through analysis to meet treatment standards as
specified in 40 CFR Part 268, Subpart D will be land disposed in a permitted facility without
further treatment. An LDR certification, including all analytical records to support the
certification, will be prepared and accompany the shipment of waste to the receiving facility.
4-14
FIGURE 4-1
Thompson Manufacturing, Inc.
Waste Generation Scenario
B
A
Process
Process
GeneratingW
astes:
Wastes
Generated:
C
CLEAN ROOM
PARTS PREPARATION
Glass
Etching
Acids
(HF)
Electroplating
Machining
(Cutting and
Shaping)
Parts Drying
With Solvents
Cleanup
Solvents
Electroplating
wastewaters
Waste Oils,
Metal
Shavings and
Scraps (NonHazardous)
F002
NWW
F003
NWW
D002W
W
D002 WW
Electroplating
wastewater
treatment
Sludge
F006
NWW
Wastewater
treatment
effluent to
POTW
4-15
4-15
PAINTING
Metallic
Paint
Components:
Lead, Mercury
D008
D009
NWW
TABLE 4-8
Thompson Manufacturing, Inc.
Identification/EPA Classification Of Hazardous Wastes Generated
1
2
3
4
5
PROCESS
GENERATING
THE WASTE
BASIS FOR
HAZARD
CLASSIFICATION
Solvent waste
Parts
preparation
Knowledge/testing
F002
Toxic
X
Waste water
treatment
sludge
Electroplating
Knowledge/testing
F006
Toxic,
potentially
reactive
X
WASTES
GENERATED
EPA
HAZARDOUS
WASTE PROPERTIES
CODE
OF WASTES
NWW
6
7
LDR
CHEMICAL ANALYSIS
WW
8
LDR TREATMENT
1
Treatment
Standard 2
Original Waste
45%
Trichlorofluoromethane
Designated
Treatment
Facility
33
Sparky
Incinerator
Solid
Stabilization
Ag <DL 5
CN (total) 3
CN (amenable)4
Cd 0.066
Cr 5.2
Pb 0.51
Ni 0.32
Ag 0.072
4-16
CN 170
Cd 210
Cr 1,500
Pb 580
Ni 1,100
Paint cleanup
solvent waste
Painting
process
Knowledge/testing
F003
Ignitable
X
Pure Acetone
160
Sparky
Incinerator
Paint sludge
Painting
process
Testing
D008,
D009
Toxic
X
Pb 460
Hg 120
Pb 5
Hg 0.2
Solid
Stabilization
Glass etching
waste
Clean room
operation
Testing
D002
Highly
corrosive
pH = 1.2
35% HF
pH = 1.2
Deactivation
Corrosive
Neutralization
1
2
3
4
5
X
Represents the highest values detected in 50 samples. The values reported for metals are for the TCLP extract in mg/l. The values reported for other
parameters are from total waste analysis in mg/kg.
This standard must be achieved to meet LDR treatment standards, if applicable. The LDR treatment standards for metals are for the constituent
concentrations in the TCLP extract of the waste in mg/l. All other standards are the concentration in the total waste analysis in mg/kg.
LDR treatment standard value for F006 in WWTP sludge is 590 mg/kg.
LDR treatment standard value for F006 in WWTP sludge is 30 mg/kg.
DL = Detection Limit (0.01 mg/l).
TABLE 4-9
Thompson Manufacturing, Inc.
Examples Of Criteria And Rationale For Selected Parameters For Wastes Generated
WASTE
WASTE PARAMETER(S)
RATIONALE FOR SELECTION
4-17
D002
(Hydrofluoric acid)
- Corrosivity (pH and steel degradation test)
Used to determine compatible sampling and storage
equipment
F006
(Wastewater Treatment
Sludge)
- Free Cyanides
Used to determine reactivity group number and levels of
cyanides in wastes. (Wastes with >150 ppm cyanide will be
stored separately from all other wastes)
- Metals (Ag, Cd, Cr, Ni, Pb)
Used to verify conformance with applicable treatment
standards.
TABLE 4-10
Thompson Manufacturing, Inc.
Examples Of Waste Sampling Methods, Equipment, And Procedures 1
WASTE
DESCRIPTION
SAMPLE COLLECTION METHOD
SAMPLING EQUIPMENT
SAMPLE PRESERVATION
AND STORAGE
4-18
Hydrofluoric Acid
Waste (D002)
Specific drums to be sampled will be selected using the
sampling method for containers as described in SW-846,
Section 9.2.3 (grab samples taken)
Polyethylene Coliwasa (inert to
hydrofluoric acid)
None required, immediate
analysis conducted
Spent Solvents
(F002, F003)
Specific drums to be sampled will be selected using the
sampling method for containers as described in SW-846,
Section 9.2.3 (grab samples taken)
Glass Coliwasa (inert to chlorinated
organics)
Storage in 250 ml amber glass
containers with teflon-lined caps
at 4 degrees Celsius
prior to analysis
Paint Sludges
(D008, D009)
Specific drums to be sampled will be selected using the
sampling method for containers as described in SW-846,
Section 9.2.3 (grab samples taken)
Glass dipper (due to high viscosity,
semi-solid physical nature of the
waste)
Storage in 250 ml amber glass
containers with teflon-lined
caps at 4 degrees Celsius
prior to analysis
Electroplating
Wastewater
Treatment Sludge
(F006)
Specific drums to be sampled will be selected using the
sampling method for containers as described in SW-846,
Section 9.2.3 (grab samples taken)
Glass dipper (due to high viscosity,
semi-solid physical nature of the
waste)
Storage in 250 ml amber glass
containers with teflon-lined
caps at 4 degrees Celsius
prior to analysis
1
Residues from sampling and analysis are subject to the waste identification requirements of 40 CFR 262.11 (hazardous waste determination),
and depending on that determination may be subject to LDR requirements.
TABLE 4-11
Thompson Manufacturing, Inc.
Examples Of Testing/Analytical Methods For Wastes Generated
SAMPLE EXTRACTION/
PREPARATION METHOD
WASTE DESCRIPTION
TESTING/ANALYTICAL METHOD
4-19
Hydrofluoric Acid (D002)
N/A
•
Corrosivity [SW-846, Method 9040 (pH
meter)]
Spent Solvents
(F002, F003)
SW-846, Method 5030 as
incorporated into SW-846, Method
8240
•
•
•
ASTM - D891, Method A for specific gravity
ASTM Method D-3278 for ignitability
SW-846, Method 8240 for acetone and
methylene chloride
Paint Sludges
(D008, D009)
Toxicity Characteristic Leaching
Procedure (TCLP) (SW-846, Method
1311 followed by SW-846, Method
3010 for lead only)
•
SW-846, Method 6010 for lead, 7470 for
mercury
Electroplating Wastewater
Treatment Sludge (F006)
Initial analysis of reactivity (cyanide)
using SW-846, Section 7.3.3.2.1 If
the waste does not meet the
definition of reactivity, SW-846
Method 3050 is used to prepare
samples for metals analysis.
•
SW-846, Method 6010 for lead; SW-846,
Method 7421 issued for cadmium, chromium,
nickel, and silver
1
F006 waste samples are tested for reactivity because if any samples exhibit the characteristic of reactivity, they are subject to
special handling procedures (containment laboratories) to ensure minimal employee exposure to toxic fumes during metals
analysis.
2 Specific gravity is measured to ensure that wastes are monophasic.
2
FIGURE 4-2
Sequence Of Procedures Sets For Determining Reactivity Group 1
START
2
VISUAL
EXAMINATION
LIQUID SLURRY,
SLUDGE
Procedure Set 1
(acid, base, redox)
FILTERABLE
SLURRY
APPARENTLY
METAL
SOLID
Procedure Set 1
(acid, base, redox)
Procedure Set 1
(acid, base, redox)
3
RGN 21, 22
AND/OR 23
Optional
Procedure Set 2
(reactivity)
LIQUID
Inorganic
Procedure Set 4
Procedure Set 6
Procedure Set 5
RGN
Procedure Set 2
(reactivity)
Procedure Set 3
(organic, inorganic)
Procedure Set 6
SOLID
Procedure Set 3
(organic, inorganic)
Organic
Procedure Set 2
(reactivity)
Filter
Organic
Procedure Set 4
Inorganic
RGN
Procedure Set 6
Procedure Set 5
RGN
RGN
1
Procedure sets are identified in EPA's "Design and Development of a Hazardous
Waste Reactivity Testing Protocol" (EPA 600/2-84-057, February 1984).
2 Based upon its knowledge of the waste, a generator may only need to use parts of the
following sequence to confirm the generator's knowledge of the material.
3 RGN = Reactivity Group Number.
4-20
4-20
RGN
Start, Stop, Continue
Procedure
Result
4-21
Sample WAP # 2 - Generator Treating to Meet LDR Treatment Standards
SAMPLE WAP #2 — GENERATOR TREATING TO MEET
LDR TREATMENT STANDARDS
Sample WAP #2 is designed to assist generators who are treating to meet LDR treatment standards
in units regulated under 40 CFR §262.34 (i.e., accumulation tanks, containers, and containment
buildings) and therefore are required to develop WAPs pursuant to 40 CFR §268.7(a)(4). While
generators who treat waste in exempt units, such as elementary neutralization units, are not specifically required to develop and maintain WAPs, many such generators will elect to develop a WAP as
a practical precautionary measure. Developing a voluntary WAP will assist the generator in fully
characterizing the properties and physical/chemical makeup of the waste. In addition, following a
detailed WAP will assist generators in monitoring for any underlying hazardous constituents in
their ignitable (D001) or corrosive (D002) wastes. (See discussion of interim final rule on ignitable
and corrosive wastes on pp. 1-15 and 1-16). In Sample WAP #2, Thompson Manufacturing neutralizes a D002 waste in an elementary neutralization unit. Because Sample WAP #2 is designed to
assist both generators who are required to develop WAPs and generators who voluntarily develop a
WAP, in the following scenario Thompson Manufacturing elects to follow the generator standards
in 40 CFR §262.34 for the elementary neutralization unit, and thus chooses to develop and follow a
voluntary WAP, although this is not specifically required.
[Note: You should review Sample WAP #1 before reviewing this sample WAP to obtain the requisite background information. Only information unique to this scenario will be included in this
sample WAP; for example, under this scenario only hydrofluoric acid wastes will be addressed. In
addition, except as necessary for clarity, only sample language is provided in this and subsequent
sample WAPs. Explanatory text can be reviewed in Sample WAP #1.]
I.
FACILITY DESCRIPTION
A.
Description Of Facility Processes And Activities
The facility description for this scenario, including waste handling procedures, is identical to that
provided in Sample WAP #1 with the following additional information regarding treatment of
hydrofluoric (HF) acid wastes. Under this scenario:
Hydrofluoric (HF) acid waste generated during glass etching processes will be transferred
from the satellite accumulation areas regulated under 40 CFR §262.34(c) to an on-site
treatment tank apparatus in compliance with the accumulation provisions of 40 CFR
§262.34(a). Neutralization of the acid wastes will be conducted in a 200-gallon polyethylene tank and will be conducted within the 90-day accumulation period afforded large quantity generators. As a result, Thompson Manufacturing is not required to obtain a hazardous
waste treatment, storage, and disposal permit provided that: 1) treatment activities are
limited to 40 CFR §262.34 accumulation tanks, containers, or containment buildings or an
exempt unit such as an elementary neutralization unit or wastewater treatment unit; and 2)
treatment of hazardous wastes is accomplished within the 90-day allowable accumulation
period (for units regulated under §262.34) (refer to Figure 4-4).
B.
Identification/EPA Classification And Quantities Of Hazardous Wastes
The identification/EPA classification of hazardous wastes (e.g., glass etching wastes) is
provided in Table 4-12. Thompson treats the HF acid waste on site using neutralization to
pH 7.1 to meet LDR treatment standards.
4-22
C.
Sample WAP # 2 - Generator Treating to Meet LDR Treatment Standards
Description Of Hazardous Waste Management Units
You should describe the design and construction of the treatment tanks as well as provide an overview
of the processes involved in the treatment. For example:
The central accumulation tank apparatus used by Thompson Manufacturing is schematically
depicted in Figure 4-5. Tank construction consists of steel-reinforced polyethylene with
special resistance to highly corrosive materials, both acidic and alkaline. The tank is
equipped with inlet and outlet piping as well as a large top port for tank maintenance and
waste sampling. Additionally, the tank has sludge removal ports that can be easily accessed to
remove any precipitation sludges arising from neutralization activities. Ancillary pumping
and mixing equipment is constructed of corrosion-resistant materials, primarily polyethylene.
HF acid waste from clean room operations is stored in accordance with the satellite accumulation provision of 40 CFR §262.34(c) in 25-gallon polyethylene DOT
17E closed head drums. When approximately 20 gallons of waste are accumulated, the drum
is transferred by dolly to the facility’s central accumulation tank. The waste is pumped into
the accumulation tank using a low horsepower portable liquid pump inert to corrosive materials. The transfer area has a cement berm, coated with an epoxy that is resistant to HF acid,
capable of containing 100 gallons. The addition of waste to the central accumulation storage
tank is recorded according to date, time, and volume in the operating log for the tank.
Through the use of this operating document, Thompson tracks the amount of waste being
accumulated and the relative time on site to ensure that the 90-day accumulation period is not
exceeded.
When the central accumulation tank has reached 50% capacity (approximately every 45 days),
neutralization of the corrosive waste is initiated. Facility personnel create an alkaline slurry
(pH of approximately 11-12) amenable to pumping by mixing 50 gallons of water with onehalf drum of caustic soda in a 100-gallon polyethylene mixing basin. This alkaline slurry is
pumped into the accumulation tank at a constant rate of 0.5 gallons per minute. Neutralization is monitored with a corrosion-resistant combination pH meter/agitator. Addition of the
alkaline slurry is continued until the pH of the waste in the accumulation tank reaches and
maintains equilibrium at a pH of 7. Subsequent to neutralization, duplicate grab samples are
taken from the accumulation tank, one through the top sampling port and another through the
discharge outlet sampling port. (See Figure
4-5.) After a 24- to 36-hour waiting period to allow for sample analysis, wastewaters are
discharged to an on-site storage tank if a pH of 7 +/- 0.5 is maintained and no other hazardous characterisics are exhibited. The volume and date of waste discharge is recorded in the
operating record for the central accumulation tank.
II.
SELECTING WASTE ANALYSIS PARAMETERS
A.
Criteria And Rationale For Parameter Selection
HF acid wastes generated by Thompson Manufacturing must be amenable to safe accumulation in tank storage for a 90-day period. Because of the uniform concentration and
monophasic nature of these wastes, the primary waste analysis parameter of concern is
corrosivity. As a result, pH measurements are taken during all facets of waste handling to
ensure that facility personnel handle these wastes in a safe manner (HF acid is particularly
dangerous to the health and safety of employees who handle the wastes) and recognize potential compatibility concerns. To supplement testing data, we have researched the
corrosive properties associated with HF acid and have selected tank and handling materials
4-23
Sample WAP # 2 - Generator Treating to Meet LDR Treatment Standards
capable of ensuring its proper containment, thereby protecting personnel and the environment.
Aside from corrosive waste concerns, Thompson’s treatment processes result in the generation
of salt precipitates which are formed during acid neutralization. These precipitates have been
tested and do not exhibit any hazardous waste characteristics. Thompson removes all precipitates from the central accumulation tanks for analysis once every 90 days for measurements
against the hazardous characteristics contained in 40 CFR §§261.21-.24. When applicable,
Thompson sends the precipitates off-site for treatment for F039 underlying hazardous constituents.
Since the operating limitations associated with Thompson Manufacturing’s short-term waste
storage are primarily the compatibility of HF acid with the tank materials and ancillary
equipment, the rationale for the selection of all waste analysis parameters were based on the
regulatory responsibility to ensure accurate waste classification and safe storage. To this end,
a combination of our process knowledge and analytical testing yielded the inventory of hazardous constituents that must be verified to confirm the accuracy and consistency of Thompson Manufacturing’s waste classification. Table 4-13 provides an overview of the parameters
selected and the rationale for selection.
B.
Special Parameter Selection Requirements
No special requirements are associated with quantifying the degree of corrosivity and related
hazards during each phase of HF acid handling at the facility, including treatment activities.
III.
SELECTING SAMPLING PROCEDURES
A.
Sampling Strategies And Equipment
We sample HF acid wastes emanating from Thompson clean room operations at four different
locations: 1) at satellite accumulation; 2) prior to transfer to the central storage/treatment
tank; 3) in the accumulation tank after treatment has been achieved; and 4) immediately prior
to discharge to the facility’s on-site wastewater storage tank. Due to the low potential for
phase separation and the uniformity of the acid waste as identified through extensive testing
and historical records, random grab samples are used to characterize HF acid wastestreams
(both treated and untreated). Refer to Table 4-10 for specific waste sampling methods, equipment, and sample handling procedures for HF acid waste.
B.
Sample Preservation And Storage
There are no sample preservation requirements associated with the HF acid treatment process
because all analyses are conducted immediately.
C.
Sampling QA/QC Procedures
All sampling conducted for the purpose of characterizing wastes generated by Thompson
Manufacturing will use appropriate QA/QC procedures, including chain-of-custody procedures from sample collection through delivery to the analytical laboratory, and compatible
storage containers. Additionally, Thompson Manufacturing will limit the number of personnel
who perform sampling to two individuals to ensure the highest levels of consistency and
accuracy. Both individuals receive annual training in the proper use of applicable sampling
and analysis equipment (e.g., pH meter).
4-24
Sample WAP # 2 - Generator Treating to Meet LDR Treatment Standards
IV.
SELECTING A LABORATORY, AND LABORATORY TESTING AND ANALYTICAL METHODS
A.
Selecting A Laboratory
We have selected Buchanan Laboratory to perform all of the detailed quantitative chemical
analysis specified in our WAP. In particular, this laboratory has:
•
•
•
B.
A comprehensive QA/QC program
Technical analytical expertise
An effective information system.
Selecting Testing And Analytical Methods
The selection of analytical testing method for the HF acid wastestream generated by Thompson Manufacturing was based on the following four considerations:
•
•
•
•
Physical state of the waste
Characteristic of interest (e.g., corrosivity)
Required pH range
Information requirements (e.g., verify compliance with LDR treatment standards, waste
classification).
Collectively, these factors contributed to the selection of the testing/analytical procedure
designated in Table 4-11. In the event that Thompson becomes subject to new regulatory
requirements, additional testing methodologies will be incorporated into Table 4-11 as appropriate.
V.
SELECTING WASTE RE-EVALUATION FREQUENCIES
In accordance with the requirements of the disposal facility used by Thompson, semi-annual
samples will be taken from the glass etching process at Thompson Manufacturing for the
purposes of conducting comprehensive physical and chemical analyses. This information will
be used to determine the appropriateness of current waste handling, storage, and characterization regimens. Specifically, these wastes will be subjected to the appropriate physical and
chemical tests for fluoride and metals.
VI.
SPECIAL PROCEDURAL REQUIREMENTS
A.
Procedures For Receiving Wastes From Off-Site Generators
Since Thompson Manufacturing does not receive wastes from off-site generators, no procedures are applicable to the receipt of off-site wastes.
4-25
Sample WAP # 2 - Generator Treating to Meet LDR Treatment Standards
B.
Procedures For Ignitable, Reactive, And Incompatible Wastes
All precautions for reactivity and incompatibility were addressed in Sample WAP #1. There are no
additional procedures for managing and treating HF acid wastes.
C.
Procedures To Ensure Compliance With LDR Requirements
Since Thompson is treating hazardous waste in tanks regulated under 40 CFR §262.34 to meet
applicable LDR treatment standards, this WAP serves to document the facility’s procedures for
complying with the LDR rules. Specifically, Sections I-V described the procedures for obtaining
representative samples of HF acid wastestreams, both before and after treatment. The results of
pre-treatment waste analysis will determine the specific treatment process requirements, including NaOH addition and treatment time, necessary to appropriately deactivate HF acid wastes to
meet the LDR treatment standards in 40 CFR 268 Subpart D. The results of post-treatment
waste analysis will determine whether the hazardous characteristic (i.e., corrosivity) has been
removed. The WAP has been filed with the appropriate EPA Regional Administrator in accordance with 40 CFR §268.7(a)(4)(ii).
In addition to the development of a WAP, Thompson will prepare appropriate LDR notifications
and certifications for waste treated on site or sent to an off-site TSDF. Records of this documentation, including waste testing results, will be maintained for a minimum of five years.
4-26
FIGURE 4-4
Schematic Of Generator Treating In 90-Day Accumulation Tanks
PROCESS NAME
Thompson Manufacturing, Inc.
Clean Room Operations
PROCESS
GENERATING WASTES
Glass Etching
Acids (HF)
D002
WW
Neutralization Tank Unit
LEGEND:
RCRA wastes/units
4-27
4-27
TABLE 4-12
Thompson Manufacturing, Inc.
Identification/EPA Classification Of Hazardous Wastes Treated In Tanks
1
2
3
4
5
6
7
CHEMICAL ANALYSIS
LDR
WASTE
GENERATED
Glass etching
acid waste
4-28
1
2
PROCESS
GENERATING
THE WASTE
Clean room
operation
BASIS FOR
HAZARD
CLASSIFICATION
Testing
EPA
WASTE
CODE
D002
HAZARDOUS
PROPERTIES
OF WASTE
Highly
corrosive
pH = 1.2
Represents the highest values detected in 50 samples.
This is the standard that must be achieved to meet LDR treatment standards.
NWW
8
WW
X
Original
Waste
35% HF
pH = 1.2
Post
Treatment
1
LDR TREATMENT
Treatment
Standard 2
Deactivation
pH = 7.1
On-Site
Treatment
Thompson
Manufacturing,
Inc., as described
in Section I.C
TABLE 4-13
Thompson Manufacturing, Inc.
Criteria And Rationale For Selected Parameters For HF Neutralization Process
WASTE
D002
(Hydrofluoric acid)
Neutralized Acid Wastewaters
WASTE PARAMETER(S)
RATIONALE FOR SELECTION
- Hydrofluoric acid concentration
Used to determine relative quantities of neutralizing agent
needed to treat waste properly
- pH
- Corrosivity towards steel
Used to determine appropriate and compatible sampling,
monitoring and storage equipment (tanks and containers)
-pH
Used to determine acceptability of neutralized wastewaters
for discharge from treatment tank to storage tank
4-29
FIGURE 4-5
Sample WAP #2 - Treatment Tank Apparatus
(Description Of Hazardous Waste Management Unit) 1
pH meter/agitation
Sample port
Flow
meter/valve
4-30
Hydrofluoric
acid
Teflon blades
Sampling port
Polyethylene Tank
(200 gallons)
Transfer area
pad w/berm
Lightweight pump
Non-hazardous
salt precipitate removal
ports
Caustic soda/water
mixing basin
Discharge to on-site
wastewater storage
tank (non-regulated)
1
Note that all storage and mixing tanks will be contained within a bermed area to contain a release in the event of tank failure.
Sample WAP # 3 - On-Site Treatment Facility (Stabilization Unit)
SAMPLE WAP #3 — ON-SITE TREATMENT FACILITY (STABILIZATION
UNIT)
[Note: You should read Sample WAP #1 before reviewing this sample WAP to obtain the requisite
background information. Under this scenario, Thompson Manufacturing operations are the same as
with Sample WAPs #1 and #2. Thompson, however, has determined that it can successfully treat, using
stabilization/solidification (S/S), two wastestreams: the wastewater treatment plant sludge (F006) and
paint wastes (D008 and D009). Thompson executives determined that they would apply for a treatment
permit under RCRA. This sample WAP will address only the S/S unit for the WAP that is required in the
RCRA permit application; in reality, Sample WAPs #2 and #3 would be merged into one WAP in the
permit application. To conserve space, we have not gone into the level of detail that you would need to
provide in your WAP.]
I.
FACILITY DESCRIPTION
A.
Description Of Facility Processes And Activities
The facility description under this scenario is identical to that provided in Sample WAP #1 with the
additional information regarding treatment using Stabilization/Solidification (S/S) of WWTP sludge and
paint wastes. We have presented this information in a process flow diagram in Figure 4-6. You should
also include a narrative description of your facility’s processes, including the pre-treatment and S/S
treatment operations, in your WAP; or, at a minimum, reference where this information may be found in
other parts of the permit application.
B.
Identification/EPA Classification And Quantities Of Hazardous Wastes
Wastes generated from Thompson Manufacturing that will be treated in the S/S treatment unit are presented in Figure 4-6 and Table 4-14. The identity of the wastes during each stage of treatment is provided in Table 4-15. A discussion of each waste presented in the figures and tables should be provided
in this section similar to what was discussed in Sample WAP #1. For example, if your WAP had Table
4-14, you might state:
The Basis for Hazard Classification (in Table 4-14, column 3) is derived from process knowledge
and testing. Process knowledge is based on knowledge that the waste is generated as described
by the listing conditions and on screening the material safety data sheets (MSDSs) prior to
accepting a purchasing agreement from a chemical or materials vendor for materials used in the
manufacturing processes. The waste classification is also verified using the testing and analytical methods specified in this WAP in Table 4-16.
C.
Description Of Hazardous Waste Management Units
Because, under this scenario Thompson is applying for a RCRA permit, the description of the hazardous
waste management units applicable to the facility’s permit application are also applicable to this WAP.
Therefore, this section will include a description of all applicable units that are used to manage hazardous wastes. Unit descriptions should include:
•
•
The drum storage accumulation area (discussed in Sample WAP #1)
The S/S unit and all its component parts.
4-31
Sample WAP # 3 - On-Site Treatment Facility (Stabilization Unit)
The S/S unit dimensions, size and throughput; S/S treatment chemicals and materials (e.g., lime, water);
and the chemical reactions and products should be described here. For example:
The S/S unit comprises the following vessels located in a bermed area adjacent to the WWT plant
(see Figure 4-7):
•
•
•
•
Paint waste holding tank (1,000 gal)
Solids collection roll-off box (40 yd3)
S/S treatment vessel (100 yd3)
Chemical/materials holding tanks, such as:
-
Water tank (2,000 gal)
Lime tank (500 gal)
Hypochlorite tank (500 gal)
Cement (bentonite) tank (100 yd3).
II.
SELECTING WASTE ANALYSIS PARAMETERS
A.
Criteria And Rationale For Parameter Selection
The criteria and rationale for selecting the parameters in Table 4-17 are:
-
The original waste, as generated
Verification of treatment operations (in process)
Determination of optimum mix ratios (during treatment)
Verification that treatment was successful (post-treatment).
At each stage of treatment, the operator will take a sample of the material and test it for critical
treatment parameters pursuant to the tables listed above.
If the wastes do not meet the in-process S/S treatment operational limitations, adjustments will be
made to the process until they are treated adequately. During treatment, the operator will take
samples to determine whether the process is proceeding appropriately per the treatment quality
control procedures. Upon completion of treatment, grab samples will be taken of each batch to
assure treatment was successful.
Each batch will be sampled to verify the success of the treatment …
B.
Special Parameter Selection Requirements
There are no special parameter selection requirements for this on-site treatment unit.
III.
SELECTING SAMPLING PROCEDURES
A.
Sampling Methods And Equipment
Sampling methods and equipment include those presented in Table 4-10 in Sample WAP #1. In-depth
descriptions of the sampling activities may also be necessary for:
•
The frequency of each sampling activity at individual sampling locations
4-32
Sample WAP # 3 - On-Site Treatment Facility (Stabilization Unit)
•
The calibration and decontamination procedures associated with the sampling procedures.
We have not addressed all of these important issues in this sample WAP. Refer to Section 2.3 of this
manual for an in-depth discussion.
B.
Sampling Preservation And Storage
We will not present site-specific information for the sampling preservation and storage requirements
since this information was covered extensively in Section 2.3.
C.
Sampling QA/QC Procedures
All sampling conducted for the purpose of characterizing wastes generated and treated by Thompson
Manufacturing will use appropriate QA/QC procedures, including chain-of-custody from sample collection through delivery to the analytical laboratory, and compatible storage containers. Additionally,
Thompson Manufacturing will limit the number of personnel who perform sampling to two individuals
to ensure the highest levels of consistency and accuracy. Both individuals receive annual training in the
proper use of sampling and analysis equipment.
IV.
SELECTING A LABORATORY, AND LABORATORY TESTING AND ANALYTICAL
METHODS
A.
Selecting A Laboratory
We have selected Buchanan Laboratory to perform all of the detailed quantitative chemical
analyses specified in our WAP. In particular, this laboratory has:
•
•
•
B.
A comprehensive QA/QC program
Technical analytical expertise
An effective information system.
Selecting Testing And Analytical Methods
Examples of the selected testing and analytical methods to be used for S/S for this WAP scenario
are provided in Table 4-16.
V.
WASTE RE-EVALUATION
Table 4-18 provides a summary of the waste testing and analysis frequencies and methods for select
parameters that might be used during the S/S treatment of Thompson’s paint sludge wastes. (Additional
parameters as found in Table 4-15 would also be applicable, as would equivalent data for the WWTP
sludge post-treatment residues.) Table 4-18 addresses the waste re-evaluation frequency and testing
methods for identification/classification of the original waste, the pre-treatment waste, during treatment
waste, and post-treatment waste. This data is necessary to monitor treatment effectiveness and to comply
with LDR requirements. For example, post-treatment data will be used to complete a Waste Profile
Sheet prior to sending the wastes to an off-site landfill.
4-33
Sample WAP # 3 - On-Site Treatment Facility (Stabilization Unit)
Per Section 2.5 of this manual, it is up to the individual facility, in consultation with regulators, to
determine the appropriate frequency of re-evaluation. There is no set formula for establishing reevaluation frequencies.
VI.
SPECIAL PROCEDURAL REQUIREMENTS
A.
Additional Procedures For Receiving Wastes From Off-Site Generators
Since Thompson does not receive wastes from off-site generators, no additional procedures are
applicable to the receipt of off-site wastes.
B.
Procedures For Ignitable, Reactive, And Incompatible Wastes
Thompson has instituted a rigorous analytical program to provide information concerning a
waste’s ignitability, reactivity, or incompatibility prior to treatment. Specifically, wastes are
evaluated against applicable hazardous waste characteristics to determine the presence of
potentially ignitable, reactive, or incompatible wastes that may damage the treatment process
and harm associated facilities/personnel. Ignitability for liquids will be determined by using
process knowledge and the appropriate Setaflash open or closed cup apparatus for the given
liquid hazardous waste. For solids, ignitibility will be based on process knowledge. Potential
reactivity characteristics will be assessed through the use of process knowledge, and for cyanide containing wastes, by applying EPA method 7.3.3.2, to determine the amount of free
cyanides released when the waste is exposed to pH conditions of 2.0. Any wastes identified as
having a potential to liberate greater than 150 mg/kg of cyanide will be considered ineligible
for treatment. Results of these analyses for original wastes, pre-treatment and post-treatment
wastes are presented in Table 4-15.
In addition to determining whether wastes exhibit hazardous characteristics, such as
ignitability, wastes are subject to a compatibility evaluation. This evaluation uses the procedures delineated in the EPA document entitled “Design and Development of a Hazardous
Waste Reactivity Testing Protocol,” February 1984, EPA 600/2-84-057. These test procedures
are used to classify wastes based on gross chemical composition for designation according to
specific reactivity groups. A general representation of the procedures to classify the waste as
acid, base, oxidizing, reducing, reactive, and primarily organic or inorganic is shown in Figure
4-2 and Figure 4-3 in Sample WAP #1.
The results of the testing procedures described in EPA 600/2-84-057 yields a reactivity group
designation (See Figure 4-3 in Sample WAP #1). Once a waste is designated, its reactivity
group is subsequently compared against the compatibility matrix, Figure 4-3 in Sample WAP
#1, to determine which wastes are compatible with each other. In cases where incompatibility
is indicated (or compatibility cannot be proven), the waste will be handled as incompatible and
sent off-site to an appropriate TSDF. We will maintain documentation of this type of information for each wastestream destined for treatment.
C.
Procedures To Ensure Compliance With LDR Requirements
S/S treatment will be performed on the two wastestreams [i.e., WWTP sludge (F006) and paint
waste residues (D008/D009)] in separate batch operations. Each treated wastestream will be
4-34
Sample WAP # 3 - On-Site Treatment Facility (Stabilization Unit)
stored on site in a covered roll-off box and sent to Rottaway Landfill as a separate waste. All
treatment equipment will be decontaminated prior to treating the other wastestream. Therefore,
for LDR purposes, each wastestream is treated as an individual waste. In accordance with the
LDR regulations (40 CFR Part 268), all treated wastes shipped off site will be analyzed to
determine whether the waste meets the applicable LDR treatment standards contained in 40
CFR §§268.41-43. Each waste destined for off-site disposal will be tested for the applicable
parameters in 40 CFR §§268.41-43 to ensure that accurate LDR notifications and certifications
are provided. All analytical results completed in support of LDR requirements will be retained
within the facility operating record.
Wastes resulting from S/S operations that exceed applicable LDR treatment standards will be
either retreated until the numeric LDR standards are met or sent off site for further treatment to
attain the numeric LDR standards. LDR notifications will be supplied with the shipment of
waste with the information required under 40 CFR §268.7. In addition to the LDR notification,
any additional data for the wastestreams (e.g., Waste Profile Sheets, analysis provided by
Thompson Manufacturing) will be provided to the subsequent permitted TSDF.
The F006 wastes that are determined through analysis to meet treatment standards as specified
in 40 CFR §§268.41-43 will be land disposed in a RCRA Subtitle C permitted facility without
further treatment. An LDR notification and certification, including all analytical records to
support the certification, will be prepared and will accompany the shipment of waste to the next
receiving facility.
The D008/D009 wastes, treated separately, can be disposed of in a Subtitle D landfill if they are
determined after treatment to have attained the LDR treatment standards and no longer exhibit
any hazardous waste characteristics.
4-35
FIGURE 4-6
Thompson Manufacturing, Inc.
Schematic Of Waste Treatment Facility Using S/S Operations 1
Thompson Manufacturing, Inc.
Thompson Manufacturing, Inc.
Parts Preparation
Electroplating Operation
Painting Operation
Metallic Paint Residues
98.8% Water
WWT Plant
Treated Water
Centrifuge
Sludge 96.8% Water
POTW
Filter Press
Liquids
(Non Hazardous)
Solids
67.6% - 72.3%
Water
Filter Cake
38.4% - 52.6% water
S/S RCRA Unit
Batch Operations
1
S/S Wastes
You may choose to provide detailed engineering drawings.
= RCRA exempt unit, per POTW discharge permit [40 CFR §261.4(a)(2), §264.1(g)(6), §265.1(c)(10)]
= RCRA Regulations apply
4-36
4-36
To Rottaway
Landfill
(Off site)
TABLE 4-14
Thompson Manufacturing, Inc.
Identification/EPA Classification Of Hazardous Wastes Treated Using S/S
1
2
3
4
5
6
7
8
CHEMICAL ANALYSIS 1
PROCESS
GENERATING
THE WASTE
BASIS FOR
HAZARD
CLASSIFICATION
WWTP Sludge
Wastewater
Treatment
Process
Knowledge/
Testing
F006
Solid
(NWW)
Storage Area A
CN 170 mg/kg
Cd 210 mg/l
Cr 1,500 mg/l
Pb 580 mg/l
Ni 1,100 mg/l
Ag <DL 6
pH = 8.0-10.0
% H O = 38.4-52.62
% organics <1%
NWW
CN (Total) 4
CN (amenable) 5
Cd .066
Cr 5.2
Pb .51
Ni .32
Ag .072
Paint Sludge
Painting
Operations
Process
Knowledge/
Testing
D008,
D009
Solid
(NWW)
Storage Area A
Pb 460
Hg 120
pH = 6.3-7.5
% H O = 67.6-72.3
% organics = 1.6-3.8
NWW
Pb 5
Hg 0.2
WASTE
GENERATED
EPA
WASTE
CODE
PHYSICAL
STATE OF
WASTES
DESIGNATED
STAGING AREA
ON SITE
TREATMENT
4-37
1
LDR
Original Waste
Treatment
Standard 3
WW or NWW
Highest values detected in 50 samples. The values reported for metals are for the TCLP extract in mg/l; the values reported for cyanide are for the
total waste analysis in mg/kg.
2Ranges found in all samples.
3This standard must be achieved to meet LDR treatment standards, if applicable. The LDR treatment standards for metals are for the constituent
concentrations in the TCLP extract of the waste in mg/l. The cyanide standard is the concentration in the total waste analysis in mg/kg.
4LDR treatment standard value for F006 in WWTP sludge is 590 mg/kg.
5LDR treatment standard value for F006 in WWTP sludge is 30 mg/kg.
DL = Detection Limit (0.01 mg/l).
6
.
TABLE 4-15
Thompson Manufacturing, Inc.
Concentration Ranges For S/S Wastes (Original Waste,
Pre- And Post-Treatment Wastes)
Ag
CN Cd
Cr
Hg
Ni
Pb
(mg/l) (mg/kg) (mg/l) (mg/l) (mg/l) (mg/l) (mg/l)
Original Waste Concentrations
pH
%
H2 O
%
Organics
1
•
WWTP Sludge
ND 0.01
130-170 180-210
•
Paint Residue Sludge
ND 0.01
ND 0.05 0.1
1,000- 0.0002
1,500
ND 0.03 80-120
900490-580 8.0-10.0 38.4-52.6
1,100
ND 0.04 420-460 6.3-7.5 67.6-72.3
1,200- 0.0002
1,600
ND 0.03 90- 130
1,000- 530-600 4.6-5.5
1,200
ND 0.04 440-480 5.7-7.8
<1
1.6-3.8
Pre-Treatment Concentrations 1
4-38
•
Filtered WWT Sludge
ND 0.01
0.076
200-240
•
Dewatered Paint Sludge
ND 0.01
ND 0.05 0.1
ND 0.01
ND 0.05 0.01-0.04 1-2
ND 0.01
ND 0.05 ND 0.01
-
-
-
-
-
Post-Treatment Concentrations 1
•
0.0002
0.1-0.2
0.3-0.4
5.9-8.3
17.5-53.7
ND 0.03 0.1-0.15 ND 0.04 0.2-0.4
6.2-8.3
18.1-48.6
S/S Treated WWT Sludge
S/S Treated Paint Sludge
1
Values reported for metals are from the TCLP extract in mg/l.
Values reported for other constituents are for total waste analysis mg/kg.
ND - Not Detected. Value given is the detection limit.
TABLE 4-16
Thompson Manufacturing, Inc.
Examples Of Testing/Analytical Methods For S/S Wastes
WASTE DESCRIPTION
SAMPLE EXTRACTION/
PREPARATION METHOD
TESTING/ANALYTICAL METHOD
Toxicity characteristic leaching
procedure (TCLP) SW-846, Method
1311, followed by SW-846, Method
3010 (for lead only).
• SW-846, Method 6010 for lead, 7470 for mercury.
Electroplating Wastewater
Treatment Sludge (F006)
Initial analysis of reactivity (cyanide)
using SW-846, Section 7.3.3.2. 1 If
the waste does not meet the
definition of reactive, use SW-846,
Method 1311, followed by SW-846,
Method 3010.
• SW-846, Method 6010 for cadmium, chromium, nickel, and lead.
4-39
Paint Sludges
(D008, D009)
1
F006 waste samples suspected of exhibiting the characteristic of reactivity are subjected to special handling procedures
(containment laboratories) to ensure minimal employee exposure to toxic fumes during metals analysis.
FIGURE 4-7
Thompson Manufacturing, Inc.
Schematic Of Batch S/S Treatment Process Unit 1
Rolloff Box
(40 yd 3 )
D Water Tank (2,000 gallons)
Conveyor
C
A
Conveyor of Dewatered
WWTP Sludge
B
4-40
Paint Waste
Residues
(D008, D009)
(10 yd 3 )
Paint Sludge Tank
1,000 gal.
S/S Treatment Vessel
(100 yd 3 )
Bermed Area
Note: The treatment area has an impermeable roof overtop.
LEGEND: A
B
C
D
1
Hypochlorite Tank (500 gallon)
Lime tank (500 gallons)
Cement (bentonite) mixer (100 yd 3 )
Water Tank (2,000 gallons)
Sample collection point
Your WAP would probably contain a detailed engineering drawing (rather than this schematic), available from (or referenced to)
other sections of your RCRA permit application.
TABLE 4-17
Thompson Manufacturing, Inc.
Criteria And Rationale For Selected Parameters*
RATIONALE
ORIGINAL
WASTE AS
GENERATED
CRITERIA
WWT Sludge
% moisture
1
(See Footnote)
PRE-TREATED
(Dewatered)
WASTES
TREATMENT IN
PROCESS
POST-TREATMENT
Paint Sludge
WWT Sludge
Paint Sludge
WWT Sludge
Paint Sludge
WWT Sludge
Paint Sludge
1
2
2
3
3
4
4
4-41
pH
1
1
2
2
3
3
4
4
% organics
1
1
2
2
3
3
4
4
TCLP metals
1
1
2
2
3
3
4
4
Ag
1
1
5
5
-
-
4
4
Ba
1
1
5
5
-
-
4
4
CN
1
1
5
5
-
-
4
4
Cr
1
1
5
5
-
-
4
4
Cd
1
1
5
5
-
-
4
4
Ni
1
1
5
5
-
-
4
4
Pb
1
1
5
5
-
-
4
4
* All analytical criteria are based on Testing and Analytical Methods, specified in Table 4-16. (The results of analysis would also need to be
provided in your WAP.)
Criteria Legend
1 To obtain waste characterization/EPA Classification.
2 To determine the optimum S/S operating parameters (conducted semi-annually for verification purposes) (i.e., determine optimum mix ratios
of treatment materials).
3 To verify treatment process operations.
To verify treatment process was successful.
4
To recharacterize waste feed (conducted semi-annually for verification purposes).
5
TABLE 4-18
Thompson Manufacturing, Inc.
Frequencies And Methods Of Testing And Analysis For S/S Paint Sludge Wastes
4-42
Post Centrifugation
During S/S Treatment
each batch
D95 or ASTM 1 D1796
each batch
ASTM D2216 PFLT
N/A
each batch
ASTM D2216 PFLT
Rate:
Method:
each batch
APHA Method 5310 2
each batch
APHA Method 5310 2
N/A
N/A
Density
Rate:
Method:
each container
ASTM D2937
each batch
ASTM D2937
each batch
ASTM D2937
each batch
ASTM D2922
Hardness
Rate:
Method:
N/A
N/A
N/A
each batch
ASTM C823-75
Comprehensive
Strength
Rate:
Method:
N/A
N/A
N/A
each batch (2 random tests)
ASTM D2166-66 or C109
Rate:
Method:
each container
ASTM D2170
N/A
once/month
CRD-611-80
N/A
Viscosity
% Solids
Rate:
Method:
each container
N/A
N/A
N/A
Permeability
Method
Rate:
Method:
N/A
N/A
each batch (10 -4-10 -8
cm/s)
each batch (10 -4-10 -8cm/s)
PARAMETER
CRITERIA
% H2 O/free
liquids
Rate:
Method:
% Organics
Original Waste
Post S/S Treatment
Note: This table would be complemented with a table that gives the criteria and rationale for testing these parameters. In addition, the desired test results should be
tabulated. The test results should be recorded and maintained in the facility operating record.
1 ASTM - American Society of Testing and Materials.
2 APHA - American Public Health Association, Standard Methods for the Examination of Water and Wastewater, 17th Edition, 1989.
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
SAMPLE WAP #4 — OFF-SITE TREATMENT FACILITY
(INCINERATOR)
[Note: You should review Sample WAP #1 before reviewing this sample WAP to obtain an understanding of the wastes to be managed by Sparky Incineration (e.g., F002 and F003 spent solvents).
The organization of this WAP varies from Sample WAPs #1, #2, and #3 to accommodate the
unique waste acceptance and handling activities that exist at a TSDF that receives wastes from off
site, such as an incineration facility. The major organizational change in this WAP is addressing
Special Procedural Requirements in Section II, rather than in Section VI. Further, the Special
Procedural Requirements Section of this WAP has been expanded to include specialized procedures
for in-process and post-process analysis requirements. An incinerator WAP will typically be very
detailed, however, due to space limitations only brief excerpts of required information are provided
here. Wherever possible, this sample WAP uses graphics to illustrate key information. You may
choose to use graphics, engineering drawings, or other schematics as well; however, each graphic
must be supported by descriptive text (which we have covered minimally in this document).]
I.
FACILITY DESCRIPTION
A.
Description Of Facility Processes And Activities
This section should include facility diagrams and an overview of the primary process (i.e., incineration), secondary processes (e.g., scrubbing the exhaust, wastewater treatment of scrubber water), and
related activities that are conducted on site (e.g., waste acceptance, management and handling activities).
Because the WAP is a component of the permit application and a final permit, a facility diagram and
description of the incineration process will probably be available from other portions of the permit
(or permit application). All information previously cited in the permit (or permit application) relevant to the WAP should be repeated, or at a minimum, referenced in the WAP. Site information
that is probably available in other RCRA permit applications sections might include a facility diagram, process activity descriptions, waste management activities, and identification and location of
waste feed areas (see Figures 4-8 and 4-9).
B.
Identification/EPA Classification And Quantities Of Hazardous Wastes Managed In
The Incinerator
Wastes received by Sparky (e.g., solvent wastes from Thompson) and treated in the incinerator
should be described in this section in detail. Table 4-19 provides an example of incinerator hazardous waste identification and EPA classification. A narrative discussion of each column in the table
should accompany the table. For example, the discussion of chemical analysis (column 7) and LDR
treatment standards (column 8) might read as follows:
The chemical characterization of the wastes received by Sparky Incineration is specified in
Table 4-19. This information includes the original chemical composition of the waste (provided by the generator) and the designated LDR treatment standards.
4-43
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
The EPA prescribed LDR treatment standard is provided in column 8. The post-treatment concentration provided in column 7 must meet or be less than the LDR treatment standard in column
8 before treatment residues can be sent off site to Rottaway Landfill for land disposal.
C.
Description of Hazardous Waste Management Units
For each unit, sufficient detail to support a discussion of the waste acceptance, handling and management
procedures must be included. There are 10 hazardous waste management units at Sparky Incineration
identified as Areas A-J in Figure 4-8. A description of each waste management unit should be provided
in the WAP, including a diagram of the waste management areas (Figure 4-8) and their physical and
chemical descriptions. The level of descriptive detail provided will vary. Generally, sufficient information should be provided to demonstrate that waste will be handled and treated safely and will prevent
releases to the environment. Examples of issues that might be discussed in the description of the waste
management units at your facility may include:
•
•
•
•
How are incompatible wastes adequately segregated?
Is all of the equipment compatible with the wastes managed?
Are the storage areas adequately bermed?
Based on the treatment capacity, is there adequate storage capacity to maintain safe
storage of incoming materials?
The 10 major waste management areas that have been provided in this example are:
•
Incinerator (Area A) (Figure 4-9)
-
•
Container storage (Area B)
-
1
Drum staging area
Air pollution control scrubber and auxiliary equipment (filter press)
Associated labs
Incoming liquid organic wastes (with included inorganic constituents)
Incoming solid organic wastes 1
•
Empty container storage (Area C) (four areas segregated according to original waste type)
•
Tank farm (Area D) (8,000 gallons each)
•
Blow down water storage tanks (Area E) (4,000 gallons each)
•
Ash hopper (Area F)
•
Scrubber sludge hopper (Area G)
•
Truck off-loading area (Area H)
•
Wastewater treatment facility (Area I)
This storage area will not be discussed in Sample WAP #4 because we are addressing only the liquid
wastes emanating from Thompson Manufacturing that are being managed at Sparky Incineration.
4-44
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
•
Waste receipt (temporary staging) and QC area (Area J)
Each unit at the facility should be described in further detail. For example, when describing the tank
farm, the size of the tanks, the number of tanks, and the composition of the wastes designated for each
tank should be provided.
II.
SPECIAL PROCEDURAL REQUIREMENTS
A.
Procedures For Receiving Wastes From Off-Site Generators
This section has been purposefully moved up to Section II (from Section VI in Sample WAPs #1, #2,
and #3) for off-site TSDFs. Generally, this section should address the pre-acceptance procedures and
incoming waste shipment procedures used to verify the identity of wastes received from off-site generators.
Pre-Acceptance Procedures (Pre-Shipment Screening)
In Sections 2.5 and 2.6 of this guidance, we described the Waste Profile Sheet as a mechanism that offsite facilities can use to determine whether a waste is acceptable. As a pre-acceptance procedure,
Sparky Incineration also requires that a Waste Profile Sheet be provided along with a representative
sample of the waste. A schematic of these procedures is provided in Figure 4-10.
Incoming Waste Shipment Procedures (Waste Acceptance Procedures)
Once a waste is approved for receipt at the facility, the incoming waste shipment procedures will be
followed. A flow diagram of these procedures, which can be augmented with text, is provided in Figure
4-11. Below is a potential excerpt from a WAP, describing the incoming waste shipment procedures.
Each day, a list of incoming shipments that are expected and have been “registered” (received
pre-approval for acceptance for that day) is made available to the guard at the receiving gate.
When wastes are received at the gate, all the accompanying paperwork (e.g., LDR notifications/
certifications, manifests, waste profile ID#) is inspected for comformance with the registration.
If there are no discrepancies in the waste shipment paperwork, the driver is instructed to proceed to the QC Area (waste receiving area, Area J). At this area, each drum is physically
inspected. A Waste Receipt Inspection Form is completed (see Table 4-20). If discrepancies in
the physical parameters are found, the container is immediately identified and brought to the
attention of the supervisor, and the procedures for resolving discrepancies with the generator
are followed (refer again to Figure 4-11).
Sparky Incineration will analyze each shipment for selected fingerprint parameters, including
chloride content, total metals, ash content, heating value, and prohibited Part 261, Appendix
VIII constituents. Sparky has established standard parameters for each sampling event. A table
of fingerprint analysis parameters for all shipments to be analyzed or tested at Sparky is provided in Table 4-21. Note that for each wastestream, a unique organic and inorganic parameter
profile will be established and that this profile is included in the Waste Receipt Analysis Report
(see Table 4-20).
4-45
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
Acceptance/rejection criteria are described completely in qualitative terms for parameters such as
color, phase, layers, turbidity, and viscosity, and in quantitative terms for parameters such as percent water, specific gravity, flash point, pH, PCBs cyanide, etc. Examples of two fingerprint/spot
check parameters and appropriate acceptance/rejection criteria follow:
EXAMPLE #1 - COLOR
The analysis of color shall consist of the use of the Grumbacher Color Compass, and appropriate
sampling procedures.
Sample Evaluation Criteria: Using the sampling procedures and the Grumbacher Color Compass,
the color of each representative sample is determined. The sixteen (16) possible color choices are:
colorless; white; brown; black; yellow; yellow-green; green; blue-green; blue; blue-violet; violet;
red-violet; red; red-orange; orange and orange-yellow. Lighter intensities of a color (equivalent to
mixtures of the color with white) are considered for purposes of this permit to be the named color.
Sample Acceptance/Rejection Criteria: The color or the representative sample of the received waste
shall be compared with the color of the pre-shipment sample. If the pre-shipment sample is colorless, white, brown, or black and the shipment sample is not that color, the waste shall be rejected.
If the pre-shipment sample is yellow, yellow-green, green, blue-green, blue, blue-violet, violet, redviolet, red, red-orange, orange, or orange-yellow, the waste shall be rejected if the color is more
than one color removed from the color of the waste, using a Grumbacher Color Compass.
EXAMPLE #2 - SPECIFIC GRAVITY
The measurement of specific gravity to satisfy the fingerprint/spot check procedures of this permit
shall consist of the use of only one of the following two methods: ASTM D891, Method A (Hydrometer) or ASTM D2111-71 (Hydrometer). Appropriate sampling procedures are described elsewhere.
Sample Evaluation Criteria: The specific gravity of each representative shipment sample shall be
determined.
Sample Acceptance/Rejection Criteria: The specific gravity of the representative sample of the
received waste shall be compared with the specific gravity of the pre-shipment sample. The shipment shall be rejected if the specific gravity of the received waste is not with 0.10 units of the specific gravity of the pre-shipment sample.
Though fingerprint analysis and screening may be adequate in many cases, additional information
may be required for off-site combustion facilities. In particular, the WAP must specify procedures that
ensure compliance with the site-specific waste feed restrictions. These restrictions are developed after the
trial burn, become part of the permit, and specify restrictions on operating conditions and waste feed composition.
At a minimum, an off-site combustion facility must analyze the wastes it receives for prohibited constituents, (e.g., PCBs; dioxin-containing wastes; reactive wastes; and Part 261, Appendix VIII constituents not
represented by the POHCs selected for the trial burn), thermal input, ash content, chloride, total toxic metals, (e.g., antimony, arsenic, barium, beryllium, cadmium, chromium, lead, mercury, nickel, selenium,
4-46
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
silver, thallium, vanadium, and zinc), and other parameters (e.g., viscosity, percent solids, solids
size, and specific gravity) as necessary.
Each batch of waste to be burned must be analyzed. A typical scenario would include: receive
waste, conduct fingerprint analysis, blend wastes in feed or burn tank, and analyze batch for
constituents and parameters discussed above. On-site facilities can have a lower frequency of
analysis but this frequency must be based on a firm statistical basis.
As noted in Section 2.5, though the generator is responsible for properly classifying the wastes,
enforcement authorities will hold the combustion facility responsible and liable for any permit
or other regulatory violation.
Whenever forms, SOPs, or other resources are used at your facility to meet a requirement, such as
waste handling procedures, copies of all these documents need to be provided in your WAP. Examples could include:
B.
•
Waste Receipt Analysis Report (See Table 4-20)
•
Procedures to Determine Reactivity of Suspicious Wastes
(See Figure 4-2 in Sample WAP #1).
Special In-Process And Post-Process Procedures
Generally, the diversity and magnitude of wastes received by off-site facilities requires specialized
in-process and post-process waste analysis procedures to ensure permit compliance, treatment
effectiveness, and safe operation. To this end, you may want to incorporate these considerations into
the “Special Procedural Requirements” section of your WAP.
In-Process Operational Procedures
This section, which is generally very detailed, may include process monitoring requirements and
protocols to meet the operating conditions of the permit. Incinerators have numerous process monitoring requirements such as testing, wastestreams, ash content, total metals, and so forth (See 40
CFR Parts 264/265 Subpart O).
All process operational procedures that are necessary must be presented and described, including any
special procedures unique to your facility. The following list of special operational procedures
activities may require attention in your WAP:
•
•
•
Decanting drums into tanks (Figure 4-12)
Solids solidification (discussed in Sample WAP #3)
Procedures for designating compatible storage units (Figure 4-13).
Any sampling and analysis procedures that are conducted in relation to these activities (such as
waste feed analysis or process monitoring) would be discussed in Section III of this WAP.
4-47
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
Post-Process Waste Handling Procedures
Post-process waste handling procedures that will demonstrate that the treatment has been successful
are based on process or permit constraints. A description of these procedures must be included in
the WAP. All of the testing, analytical, and monitoring requirements that will be necessary to make
this demonstration should be included in the WAP. The appropriate testing to meet LDR requirements [40 CFR 268.7(b)] should also be addressed. Consequently, for Sparky this section may
address waste analysis and waste handling of the following residue streams:
•
•
•
•
Ash
Scrubber sludge
Refactory brick waste
Blowdown waters.
The sampling and analysis and monitoring procedures for all post-process wastes should be described in Section III of this WAP.
Recordkeeping
As part of your facility operating record, all portions of your WAP, including procedures and sampling results, should be kept on site.
C.
Procedures For Ignitable, Reactive, And Incompatible Wastes
Sparky Incineration has instituted a rigorous analytical program to provide information
concerning a waste’s ignitability, reactivity or incompatibility prior to treatment. Specifically, incoming wastes are evaluated against applicable hazardous waste characteristics to
determine the presence of potentially ignitable, reactive, or incompatible wastes that may
damage the treatment process and harm facilities/ personnel. Ignitability data for liquids
will be obtained by using process knowledge and the appropriate Setaflash open or closed
cup apparatus for the given liquid hazardous waste.
Potential reactivity characteristics will be assessed through the use of both process knowledge and, for cyanide containing wastes (that may be generated by generators other than
Thompson), by applying EPA method 7.3.3.2 to determine the amount of free (potentially
reactive) cyanides released when the waste is exposed to pH conditions of 2. Any wastes
identified as having a potential to liberate greater than 150 mg/kg of cyanide will be considered ineligible for treatment by Sparky Incineration.
In addition to determining whether wastes designated for treatment exhibit hazardous characteristics, such as ignitability, wastes received for incineration at Sparky Incineration are
subjected to a compatibility evaluation. This evaluation uses the procedures delineated in
the EPA document entitled “Design and Development of a Hazardous Waste Reactivity
Testing Protocol,” February 1984, EPA 600/2-84-057. These test procedures are used to
classify wastes based on gross chemical composition for designation according to specific
reactivity groups (refer to Figure 4-2 and Figure 4-3 in Sample WAP #1).
The results of the testing procedures described in EPA 600/2-84-057 (refer to Figure 4-2 in
Sample WAP #1) yields a reactivity group designation. These designations are subsequently
compared against the compatibility matrix, Figure 4-3, to determine the potential effects of
4-48
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
mixing with wastes of other reactivity groupings. In cases where incompatibility is indicated (or
compatibility cannot be proven), the waste will be handled as incompatible and will be ineligible for treatment by Sparky Incineration. We will maintain documentation of this type of
information for each wastestream received for treatment.
D.
Procedures To Ensure Compliance With LDR Requirements
A facility that accepts wastes from off-site generators, treats wastes on site, and sends wastes off site for
further treatment and disposal must be concerned with LDR requirements during waste acceptance, onsite waste management (i.e., treatment) and shipment off site. Sparky Incineration, for example, should
incorporate LDR considerations into the following procedures:
•
•
•
•
Pre-Acceptance Procedures
Incoming Waste Shipment Procedures
Process Operational Procedures
In-Process and Post-Process Waste Handling Procedures.
Sample language from Sparky Incineration’s WAP may include:
Wastes received at Sparky Incinceration will initially be subjected to a review of the accompanying LDR notification along with the preliminary inspection given to the wastes. Any discrepancies in the LDR notification and the associated manifest, analytical records, or Waste Profile
Sheet will deem the shipment ineligible for receipt unless additional clarifying information can
be provided by the generator. All information obtained to document LDR compliance will be
maintained in the facility operating record. For a continuous incineration process, Sparky
Incineration will also provide its procedures for determining which waste codes and accompanying LDR treatment standards apply to specific batches of ash.
Incineration residues remaining after treatment of wastes (received from Thompson Manufacturing and other generators) will require off-site disposal as a result of the derived-from-rule
for listed wastes or if the residue exhibits hazardous characteristics. In accordance with the
LDR regulations (40 CFR Part 268), all wastes shipped off site will be analyzed to determine
whether the waste meets the applicable LDR treatment standards contained in 40 CFR
§§268.41-43. Testing of results will be used to ensure that accurate LDR notifications and
certifications are provided. All analytical results completed in support of LDR requirements
will be retained within the facility operating record.
Wastes resulting from Sparky Incineration’s operations that exceed applicable LDR treatment
standards will be sent for further off-site treatment to meet LDR treatment standards in 40 CFR
§§268.41-43. LDR notifications will be supplied with the shipment of waste and will contain the
information required under 40 CFR §268.7. In addition to the LDR notification prepared by
Sparky Incineration, any additional relevant and applicable data obtained from the generators
(e.g., Waste Profile Sheets, original LDR notifications, analysis provided by generators) will be
provided to the subsequent permitted TSDF where incineration residues will be sent.
Wastes that are determined through analysis to meet treatment standards as specified in 40 CFR
§§268.41-43 will be land disposed in a RCRA Subtitle C permitted facility without further
treatment. An LDR notification and certification, including appropriate analytical records to
4-49
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
support the certification, will be prepared and supplied with each shipment of waste to the
receiving facility.
III.
IDENTIFICATION OF WASTE PARAMETERS
A.
Criteria And Rationale For Parameter Selection
Table 4-22 gives examples of incinerator parameter criteria and rationale that would be applicable to
incoming waste materials. The criteria and rationale for parameter selection are designed to meet
treatment operating conditions (e.g., equipment limitations), permit operating conditions, and special
regulatory requirements such as compliance with LDR requirements (40 CFR Part 268). Parameters
selected to demonstrate conformance with operating (40 CFR §264.345) and permit conditions include
prohibited 40 CFR Part 261, Appendix VIII constituents; heating value; ash content; chloride content;
total metals; viscosity; percent solids; solids size; and specific gravity.
B.
Special Parameter Selection Requirements
In many cases, special parameters should be tested to ensure that the wastes meet permit conditions.
An example of a special parameter for your facility might include sampling for the presence of PCBs,
which are regulated under the Toxic Substances Control Act (TSCA) and generally are not regulated
under RCRA. (Although PCBs may be regulated as a California List Waste under the LDR requirements and regulated under RCRA by some states.)
IV.
SELECTING SAMPLING PROCEDURES
An overview of the operations which require sampling and analysis is provided in Figure 4-14, and the
sampling associated with decanting liquids is provided in Figure 4-12. Generally, testing and analysis
will be required during all three phases of treatment:
pre-process, in-process, and post-process.
A.
Sampling Strategies And Equipment
Your WAP must address the appropriate sampling method for obtaining a sample of each parameter
for every waste. Table 4-23 provides as an example tabular format to represent sampling information
specific to your operations. This type of table should be accompanied by supporting narrative.
B.
Sample Preservation And Storage
We will not present site-specific information for the sampling preservation and storage requirements
since this information was covered extensively in Section 2.3. You should provide similar information in your WAP.
C.
Sampling QA/QC Procedures
All sampling conducted for the purpose of characterizing waste generated or treated by Sparky Incineration will use appropriate QA/QC procedures, including chain-of-custody from sample collection
through delivery to the analytical laboratory, and compatible storage containers. Additionally, Sparky
4-50
Sample WAP # 4 - Off-Site Treatment Facility (Incinerator)
Incineration will limit the number of personnel who perform sampling to two individuals to ensure the
highest levels of consistency and accuracy. Both individuals receive annual training in the proper use
of sampling and analysis equipment.
V.
SELECTING A LABORATORY, AND LABORATORY TESTING AND ANALYTICAL METHODS
A.
Selecting A Laboratory
We have selected Buchanan Laboratory to perform all of the detailed quantitative chemical
analyses specified in our WAP. In particular, this laboratory has:
•
•
•
B.
A comprehensive QA/QC program
Technical analytical expertise
An effective information system.
Selecting Testing And Analytical Methods
The selection of analytical testing methods for wastestreams received and treated at Sparky
Incineration was based on the following considerations:
•
Physical state of the waste
•
Analytes of interest
•
Required detection limits
•
Information requirements (e.g., verify compliance with LDR
standards).
VI.
treatment
SELECTING WASTE RE-EVALUATION FREQUENCIES
The selected re-evaluation frequency for wastes treated in the incinerator must be established for waste
acceptance, waste handling (e.g., blending), and waste treatment in the incinerator. At a minimum,
each batch of waste burned will be analyzed for prohibited 40 CFR Part 261, Appendix VIII constituents; total metals; PCBs; dioxin-containing wastes; heat value; ash content; chloride; viscosity; solids
content; solids size; and specific gravity.
In addition, the trial burn, permit application, and permit must specify the frequency for sampling
operating parameters unique to incinerators (40 CFR §§270.19, 264.344, and 265.341). Refer to
Section 2.5 of this manual for assistance.
4-51
FIGURE 4-8
Sparky Incineration, Inc. Facility Layout
Temporary
Staging Area/QC
Area (Area J)
Container Storage
(Area B)
Main
Gatehouse
Parking
1
Lab #5
B.1
B.2
Empty
55-Gallon
Drum Storage Drum Storage
Truck OffLoad Areas
(Area H)
Wastewater
Treatment Facility
(Area I)
Tank Farm
(Area D)
Blowdown Water
Storage Tanks
Area E
4-52
Drum Staging
Drum
Staging
Drum Staging
Air Pollution
Control
Equipment
Drum Staging
Sump
Lab
Filter
Press
Area A
Scrubber Sludge
Hopper (Area G)
Lab
Empty Container
Storage
(Area C)
Lab
Offices
N
Not to Scale
1
Emergency
Equipment Storage
Trailer
Storage
Trailer
Sample
Storage
Control
Room
Ash Hopper
(Area F)
Incinerator
Area A
A detailed diagram of each hazardous waste management unit (Areas A-H) would be provided if necessary.
55-Gallon
Drum Storage
Empty Drum
Storage
FIGURE 4-9
Sparky Incineration, Inc.
Treatment System
1
Flue Gas
Hopper
APCD
7
6
4
3
4-53
Conveyed to storage yard (roll-off box)
5
2
1
SOLID WASTE (Fiber Drums)
2
BARREL CHARGING
3
LIQUID WASTE FEED
4
EXHAUST AIR FROM TANKS
5
AUXILIARY FUEL OIL
6
LIQUID FUEL FROM TANK FARM
7
AIR POLLUTION CONTROL UNIT
Ash
Hopper
Rotary Kiln
Afterburner
Ash
TABLE 4-19
Sparky Incineration, Inc.
Identification/EPA Classification Of Hazardous Wastes Treated By Incineration
1
2
3
4
5
6
DISPOSITION
ON SITE
WASTE
GENERATOR
NAME, WASTE
PROFILE #
7
8
CHEMICAL ANALYSIS
TREATMENT
LDR
PROCESS
GENERATING
THE WASTE
BASIS FOR
HAZARD
1
CLASSIFICATION
EPA
WASTE
CODE
PHYSICAL
Designated Waste
STATE OF
Original
Management
Staging
WASTES
Waste1
Area
Post
Treatment 2
(mg/kg)
NWW
WW
Designated
Treatment
Standard 3
(mg/kg)
Parts
Preparation
(Parts Drying)
Process
Knowledge/Testing
F002
Liquid
Area B (Incoming
Liquids)
35%
CFC-11
(trichlorofluoromethane)
2
X
33
Thompson
Manufacturing
WPN 239 4
Painting
(Cleanup
Solvents)
Process
Knowledge/Testing
F003
Liquid
Area B (Incoming
Liquids)
98%
acetone
10
X
160
4-54
Thompson
Manufacturing
WPN 683 4
1
Provided by the generator
2 Values shown are for the total waste analysis.
3 The EPA treatment method or alternative will be specified. (Value shown is for the total waste analysis.)
4 WPN = Waste Profile Number
FIGURE 4-10
Sparky Incineration, Inc.
Pre-Acceptance Procedures
G
E
N
E
R
A
T
O
R
A
C
T
I
V
I
T
I
E
S
Pre-Acceptance Criteria
Is waste acceptable in the facility
permit?
GENERATOR
CONTACTS FACILITY
Will treatment of this waste cause
operation problems?
WASTE PROFILE IS
SUBMITTED
Is the waste reactive or does it
require special handling?
Can waste be treated to meet LDR
standards?
REPRESENTATIVE
SAMPLE IS SUBMITTED
Will treatment of this waste jeopardize
incinerator's ability to meet LDR
standards for process residuals?
Sample is analyzed and compared
to waste profile sheet data.
Discrepancy Exists
No Discrepancies
(Waste is Approved)
Designate Compatible
Storage Area for Waste
Containers
Contact Generator
Resolve Discrepancy
No Resolution:
Reject Waste
Shipment
Determine Proper Waste
Handling Procedures at
Incinerator
Complete Waste
Profile, Assign Internal
Waste Registration #
Schedule Waste
Shipment
4-55
4-55
Designate Compatible
Tank Storage for Bulk
Materials
Notify On-site Laboratory of
Waste Analysis/Fingerprint
Analysis Procedures
Fill Out Waste Acceptance
Sheet (Specific Sampling
Materials and Equipment)
FIGURE 4-11
Sparky Incineration, Inc.
Incoming Waste Shipment Procedures
(Waste Acceptance Procedures)
Waste Shipment Arrives
At Gate Compare Shipment
Externally to Its Manifest and
LDR Notification
At QC Area Visually Inspect
Shipment and Compare to
Waste Profile Description
Discrepancy
2
Contact
Generator
Fill Out Waste Receipt
Inspection Form
Sample Waste Parameters
Lab Pack Auditing
Analyze Waste Parameters
Evaluate Analytical Data
1
Random Sampling for PCBs
and Dioxins
Discrepancy
Reject Waste
Shipment
Contact Generator
Evaluate Analytical Data
Recharacterize Waste
Accept Waste Shipment
Store Waste in Designated
Storage Area
1
2
Each time a new waste is shipped, and at least twice a year, the waste is re-analyzed for all Waste Profile parameters.
If discrepancy is found, the next shipment from this generator is subject to increased level of analysis.
4-56
4-56
TABLE 4-20
1, 2
Example Waste Receipt Analysis Report
Generator:
Profile Number:
Date Received:
Waste Name:
Transporter:
Work Order Number:
Trailer Number:
Manifest Number:
Line No. of No.
Waste Codes:
Authorization #:
PCB / Non-PCB
Approved As:
Manifested Qty
Received As:
Received Qty
Fingerprint Parameters
Test
Screen
Analysis
4-57
Physical
Description
SWAR
Profile
Received
Conforms
Analyst
Storage Area:
Drum Numbers:
gals.
X
X
gals.
Test
Compatibility Group:
Profile
Received
SWAR
thru:
Conforms
Oxidizer
Yes
No
Flam Pot
Yes
No
CN
Radioactivity
Yes
Yes
No
No
Water Mx
pH
Yes
Yes
No
No
SP. Gr.
Yes
No
% CI
Yes
No
% Water
Yes
No
%F
Yes
No
% Ash
Yes
No
% Br
Yes
No
Btu/lb
Yes
No
%S
Yes
No
PCB mg/kg
Yes
No
Compatibility
Yes
No
Color
Phases
Yes
Yes
No
No
Yes
Yes
No
No
Layers
Yes
No
Paint Filter
Viscosity
Turbidity
Yes
No
Analyst
Discrepancies
Resolution:
NonConformity Contact Person/Company:
Sampling Information
Phone Number:
Date:
Time:
Date:
Time:
Comments:
Container No.'s Sampled:
Manifest Info Correct: Yes No
Supplemental Analysis Required
Signature:
Sampler's Name:
Burn Approval:
Yes
No
Yes No
Repack Approval:
No
If Yes, Attach Analysis
Yes
Maximum lbs/Container
Maximum # of Charges/Cycle:
Date:
Time:
No
Lab Number Due to:
Signature:
Received Waste Conforms To Preacceptance Analysis and Should
Be Accepted.
Yes No
Date:
Time:
Chemist's Name
Yes
Storage Compatibility Test Required:
Total No. of Samples:
Sample Delivery to Lab:
Received By (Name):
Date:
Name:
Signature:
1
2 Complete only those items that are applicable to your TSDF.
Pump Drum Approval:
To Be Pumped As:
Yes
No
Date:
Second Fuel
Time:
Chemist's Name
Signature:
Each TSDF should develop acceptance/rejection criteria for fingerprint parameters and should include those on a form similar to this example.
Lean Water
TABLE 4-21
Sparky Incineration, Inc.
Fingerprint Analysis Used To Sample Incoming Wastes
CHEMICAL PARAMETERS
PHYSICAL PARAMETERS
Cyanide*
PCBs*
% CI*
% F*
% Br*
% S*
Organic Parameters**
(Prohibited Part 261,
Appendix VIII
Constituents) Inorganic
Parameters
(Total metals)**
% Ash
% Water*
Radioactivity*
Specific Gravity*
Flammability*
Flash Point*
pH*
Water Reactive
Heating Value
VISUAL PARAMETERS
Color*
Phases*
Viscosity*
Turbidity*
Layers*
* Checked each time the waste is shipped (other parameters are tested only when initial or updated
representative samples is provided.
** Unique parameters will be selected for each waste stream and designated in the Waste Profile
Sheet.
4-58
4-58
FIGURE 4-12
Sparky Incineration, Inc.
Examples Of Pre-Process, In-Process, And Post-Process
Activities Related To Decanting
PRE-PROCESS
IN-PROCESS
POST-PROCESS
LIGHT
HYDROCARBONS
SETTLED
SOLIDS
CHLORINATED
HYDROCARBONS
4-59
CONTAINER
WASTE FROM
STORAGE
(e.g., Liquid
Waste)
DRUM GROUPING
EVALUATION
WASTE PROFILE
SHEET AND OTHER
PERTINENT
INFORMATION
DECANTING
PROCESS
TO DESIGNATED PREPROCESS STORAGE AND
PREPARATION
TANKS/CONTAINERS
(See Figure 4-14, PreProcess Section)
Split
Sampling for
Regulatory
Parameters/
Final
Approval
AQUEOUS
PHASE
INCINERATION
SOLID RESIDUES
SOLIDS
DECANTED/EMPTY
CONTAINERS
= Sample
TO OFF-SITE
DISPOSAL OR
RECLAMATION
FIGURE 4-13
Sparky Incineration, Inc.
Procedures For Designating Compatible Storage Units
STORAGE
EVALUATION
*
INFORMATION
REGARDING EXISTING
STORAGE CONTENTS
4-60
•
INFORMATION
REGARDING EXISTING
STORAGE MATERIALS
OF CONSTRUCTION
•
ANALYSES (AS
NECESSARY) *
e.g., reactivity
COMPATIBLE
APPROPRIATE
STORAGE
UNIT
INCOMPATIBLE
SELECT ANOTHER
STORAGE UNIT
REJECT
* Your WAP should designate the types of analysis or parameters that will be necessary to conform or
deny the storage of wastes in designated storage units.
TABLE 4-22
Sparky Incineration, Inc.
Examples Of Selected Parameter Rationale, Criteria, And Special
Considerations
WASTE
F002
PARAMETERS
CRITERIA
RATIONALE
33 mg/kg 1
trichlorofluoromethane (CFC-11)
acetone
F003
To determine if LDR
prohibition levels are
exceeded
F002, F003
Heat of
Combustion
To determine if LDR
prohibition levels are
exceeded
>60° Celsius
To verify waste
identification and to
identify ignitables for safe
handling
1,000 Btu/lb. minimum
heat of combustion is
permit limit
To assess burning
efficiency
None
None
PCBs
All Wastes
1
F002 and F003, including
incinerator residuals (e.g.,
ash), must meet applicable
LDR treatment standards
before land disposal
None
160 mg/kg 1
Ignitability
F002, F003,
SPECIAL
CONSIDERATIONS
PCBs not acceptable in the
To determine presence in facility permit above 50
sample
mg/kg
50 mg/kg
These analyses would be used to demonstrate compliance with LDR treatment standards after treatment by
incineration.
4-61
4-61
FIGURE 4-14
Sparky Incineration, Inc.,
Hazardous Waste Sampling Flow Diagram
Initial Approval at
Gate Area
PRE-PROCESS
Sample/Analyze/Verify
Waste at QC Area/
Temporary Storage Area
Final
Approval
Waste Storage and
Preparation (Blending)
IN-PROCESS
Incineration
(Operating Parameters
Verified)
Ash
Scrubber Water
Shipment for Off-Site
Disposal
Activities/Processes That Require Sampling
4-62
4-62
To Sewer
POST-PROCESS
Residue Storage Prior
to Disposal
Wastewater
Treatment
TABLE 4-23
Sparky Incineration, Inc.
Examples Of Sampling Methods And Equipment Used
SAMPLE
MATERIAL
SAMPLE
METHOD
a
SAMPLE
EQUIPMENT
Fly ash-like material
ASTM D 2234-76 or
ASTM E 300 a
Tube sampler d, trier,
auger, scoop, or shovel
Containerized liquids
(e.g., tank, drums) c
SW-846 b or
ASTM E 300 a
Coliwasa/tube sampler d,
weighted bottle, bomb, or
tank sampling ports
a --
b --
c --
d --
American Society for Testing Materials, 1982. Annual Book of ASTM Standards, Philadelphia, PA,
or most recent edition.
Test Methods for Evaluating Solid Waste, 1980, SW-846, 2nd Edition, U.S. Environmental
Protection Agency, Office of Water and Waste Management, Washington, DC, or most recent
edition.
The specific equipment is dependent on the type of container. See SW-846 for specific examples.
See also Section 2.2.
Personal Protection and Safety Training Manual (Cincinnati, Ohio: U.S. Environmental Protection
Agency, National Training and Operational Technology Center, 1981), pp. 3-1 and 3-4.
4-63
4-63
Sample WAP # 5 - Landfill
SAMPLE WAP #5 - LANDFILL
[Note: You should review Sample WAP #1 before you review this sample WAP to obtain an understanding of the wastes to be managed by Rottaway Landfill (e.g., treated F002, F003, D008, and D009
wastes). The organization of this WAP is similar to the organization of the incinerator WAP and,
therefore, varies from the organization of Sample WAPs #1, #2, and #3 to accommodate the unique
waste acceptance and handling activities that exist at a TSDF that receives wastes from off site, such
as a land disposal facility. The major organizational change in this WAP is addressing the Special
Procedural Requirements in Section II, rather than in Section VI. Further, the Special Procedural
Requirements Section has been expanded to include unique waste analysis and evaluation requirements
necessary for proper landfill operation. A landfill WAP will generally be very detailed, however, due to
space limitations in this guidance manual only brief excerpts of required information are provided here.
Wherever possible, this sample WAP uses graphics to illustrate key information. You may choose to use
graphics, engineering drawings, or other schematics as well; however, each graphic must be supported
by descriptive text (which we have covered minimally in this document).]
I.
FACILITY DESCRIPTION
A.
Description Of Facility Processes And Activities
This section should include facility diagrams and an overview of the landfill activities (e.g., waste acceptance, handling and management activities) that are conducted on site.
Because the WAP is a component of the permit application and a final permit, a facility diagram and
description of the site activities will probably be available from other portions of the permit (or permit
application). All information previously cited in the permit (or permit application) that is relevant to the
WAP, should be repeated in the WAP or, at a minimum, referenced in the WAP. For example, information that is probably available in other RCRA permit application sections may include a facility
diagram; a general description of the types and quantities of wastes received, stored, and landfilled (see
Section I.B below); a brief description of the activities that are relevant to waste handling procedures and
the identity and locations of waste staging and storage areas. (See Figures 4-15 and 4-16.) For clarity,
you may choose to present this information in tabular or graphic formats with supportive text.
B.
Identification/EPA Classification And Quantities Of Hazardous Wastes
Wastes received at the landfill are described in this section. We have provided the list in tabular form in
Table 4-24. A discussion of each column in the table should accompany the table. For example, the
discussion of Chemical Analysis (column 7) and LDR treatment standards (column 8) might read as
follows:
The chemical characterization of the wastes received at Rottaway is specified in Table 4-24. This
information includes the chemical composition of the treated waste (provided by the generator)
and the designated LDR treatment standards.
4-64
Sample WAP # 5 - Landfill
The EPA prescribed LDR treatment standard is provided in column 8. The post- treatment concentration provided in column 7 must meet or be less than the LDR treatment standard in column 8
prior to land disposal.
C.
Description Of Hazardous Waste Management Units
There are 10 hazardous waste management units at Rottaway Landfill. A description of each is
provided below. This description includes a diagram of the facility layout (Figure 4-15) and the
waste management areas (Figure 4-16).
•
•
•
•
•
•
•
•
•
•
Main Gate (Area A)
Container Storage (Area B)
Container Storage (Areas C and D)
Container Storage (Area E)
Cell A (Area F)
Cell B (Area G)
Cell C (Area H)
Cell D (Area I)
Temporary Drum Storage (Area J)
Incompatibles Storage (Area K).
The waste management and handling procedures in each unit at the facility should be described in further
detail. Physical parameters relevant to these procedures should also be provided. For example, when
describing the drum storage areas, information such as the size and number of containers, and the composition of the wastes designated for each area should be provided.
II.
SPECIAL PROCEDURAL REQUIREMENTS
A.
Procedures for Receiving Wastes From Off-Site Generators
This section has been purposefully moved up to Section II (from Section VI in Sample WAPs #1, #2, and
#3) for off-site TSDFs. Generally, this section should address the pre-acceptance procedures and incoming
waste shipment procedures used to verify the identity of waste received from off-site generators.
Pre-Acceptance Procedures (Pre-Shipment Screening)
In Sections 2.5 and 2.6 of this manual, we described the Waste Profile Sheet as a mechanism that off-site
facilities can use to obtain the detailed physical and chemical description of each waste stream from the
generator.
Rottaway Landfill requires that the off-site generator supply a Waste Profile Sheet and a representative
sample of the waste. Figure 4-17 shows how the Waste Profile Sheet is used as a component of the PreAcceptance Procedures that are followed at Rottaway.
Incoming Waste Shipment Procedures (Waste Acceptance Procedures)
After a waste is approved for receipt at the facility, the wastes are subjected to incoming waste procedures
shown in Figure 4-18. Each step of these procedures must be described in detail. For example:
4-65
Sample WAP # 5 - Landfill
Rottaway’s wastes acceptance and handling procedures [developed in conformance to 40 CFR
264.13(c)] include ensuring that the information provided by the generator is correct and
verifiable. In addition, Rottaway will generate independent information by physically inspecting each wastestream and testing for fingerprint analysis parameters.
A sample is extracted from each container using the methods and equipment specified in the
Waste Acceptance Sheet (a Sample Waste Acceptance Sheet is not provided in this sample
WAP). The sample is analyzed for the individual fingerprint analysis parameters specified for
that waste, per Section III of this WAP (see Table 4-25).
A Waste Receipt Analysis Report is filled out (see Table 4-20). If discrepancies are found, the
container is immediately identified and brought to the attention of the supervisor, and the
procedures for resolving discrepancies with the generator are followed (see Figure 4-18).
[Note: Although fingerprint analysis is acceptable for initial acceptance of an incoming
waste, a thorough analysis of all appropriate LDR regulated constituents is required for each
batch prior to land disposal.]
The criteria for selecting fingerprint analysis parameters are provided in Sections 2.5 and 2.6 of this
manual. In general, these are developed as a screening guide for determining whether incoming wastes
as received will conform to the Waste Profile Sheet (See Figure 4-17).
B.
Special Landfill Waste Analysis And Evaluation Procedures
Given the magnitude and diversity of waste potentially received by landfill operations, specialized
waste analysis and evaluation procedures are necessary to ensure permit compliance, landfill unit
integrity, and safe waste disposal. To this end, you will want to include unique waste analysis provisions or protocols in the “Special Procedural Requirements” section of your WAP. For example:
On-Site Waste Management and Handling
After initial acceptance of a waste at Rottaway Landfill, the proper landfill cell is determined
based upon the following information:
•
•
•
•
Waste receipt analysis report
Fingerprint analyses
Comprehensive sample analyses
Generator information.
Collectively, this data is used to carry out the landfill cell designation procedures illustrated in
Figure 4-19.
Once an appropriate designation has been made, the waste can be moved from the temporary
storage (Area J) to long-term container storage (Areas C and D). If necessary, appropriate
steps will be conducted to ensure that all landfilled wastes have no free liquid content. Moisture content and paint filter liquids tests should be conducted before and after any waste pretreatment to remove liquids content. A waste identification review is performed after any pre-
4-66
Sample WAP # 5 - Landfill
treatment to identify changes in the wastes classification or physical/chemical properties that
may affect its acceptability for disposal in accordance with LDR requirements or the facility
permit.
Prior to actual placement of waste into one of Rottaway’s landfill cells, the relevant analysis for
appropriate LDR regulated constituents of the waste will be reviewed to verify the acceptability
of the waste for disposal. The identity of the waste, including any physical/chemical changes
that have occurred during storage or liquids removal is reviewed for permit compliance and
potential incompatibilities with existing landfill wastes and components. After approval, the
container contents and registration number are recorded and disposal initiated.
C.
Procedures For Ignitable, Reactive, And Incompatible Wastes
Rottaway Landfill has instituted a rigorous analytical program to provide information concerning a waste’s ignitability, reactivity, or incompatibility prior to treatment. Specifically, incoming wastes are evaluated against applicable hazardous waste characteristics to determine the
presence of potentially ignitable, reactive, or incompatible wastes.
Potential reactivity characteristics will be assessed through the use of both process knowledge
and, for cyanide-containing wastes (that may be generated from generators other than Thompson), by applying EPA method 7.3.3.2 to determine the amount of free (potentially reactive)
cyanides released when the waste is exposed to pH conditions of 2. Any wastes identified as
having a potential to liberate greater than 150 mg/kg of cyanide will be considered ineligible for
disposal at Rottoway Landfill.
In addition to determining whether wastes exhibit hazardous characteristics, wastes received at
Rottaway Landfill are subjected to a compatibility evaluation. This evaluation uses the procedures delineated in the EPA document entitled “Design and Development of a Hazardous Waste
Reactivity Testing Protocol,” February 1984, EPA 600/2-84-057. These test procedures are
used to classify wastes based on gross chemical composition for designation according to
specific reactivity groups (refer to Figure 4-2 and Figure 4-3 in Sample WAP #1).
The results of the testing procedures described in EPA 600/2-84-057 (refer to Figure 4-2 in
Sample WAP #1) yields a reactivity group designation. These designations are subsequently
compared against the compatibility matrix, Figure
4-3, to determine the potential effects of mixing with wastes of other reactivity groupings. In
cases where incompatibility is indicated (or compatibility cannot be proven), the waste will be
handled as incompatible and will be ineligible for land disposal at Rottaway. We will maintain
this type of information for each wastestream received for disposal.
D.
Procedures To Ensure Compliance With LDR Requirements
A facility that accepts wastes from off-site generators for disposal must be concerned with LDR requirements in waste acceptance and on-site waste management. Prior to waste shipment approval,
Rottaway’s pre-acceptance procedures (see Section II.A of this WAP) should be used to screen wastes
for LDR compliance when wastes are received on site. The incoming waste procedures require that all
documentation (e.g., manifest, the LDR notification and certification) be reviewed against waste profile
descriptions and the sample analytical results.
4-67
Sample WAP # 5 - Landfill
Upon waste receipt, discrepancies in the LDR notification/certification and the associated manifest,
analytical records, or waste profile sheet will deem the shipment ineligible for disposal unless additional clarifying information can be provided by the generator. The incoming waste acceptance procedures (see Section II.C of this WAP) also require that a physical inspection be conducted to ascertain
whether the waste is in fact meeting LDR requirements. All information obtained to document LDR
compliance will be maintained in the facility operating record (see Waste Management and Handling
Procedures in Section II.C of this WAP).
III.
IDENTIFICATION OF WASTE PARAMETERS
A.
Criteria And Rationale For Parameter Selection
The criteria and rationale for the selection of all wastes analysis parameters must be included in the
WAP. This selection of parameters is based on the factors given in Section 2.2 of this guidance
manual. An example of some of the waste parameter selection criteria and rationale for Rottaway
Landfill is presented in Table 4-26. These parameters should be discussed in detail in your WAP.
B.
Special Parameter Selection Requirements
The WAPs for landfills must include provisions for the selection of special parameters necessary to
ensure permit compliance and proper operation of the facility. For landfills, this portion of your WAP
should address the waste analysis parameters and tests that will be performed to ensure compliance
with the special requirements for bulk and containerized liquids in 40 CFR §§264/265.314. Specifically, these should include, at a minimum, moisture content and paint filter liquid test evaluations to
provide assurance that wastes being landfilled contain no free liquid content. Additional special
parameters may be required to meet unique permit requirements specific to your operation.
IV.
SELECTING SAMPLING PROCEDURES
Section 2.3 of this guidance manual highlighted the components of a Sampling Procedures Section of a
WAP, which should include:
A.
B.
C.
A.
Sampling Methods and Equipment
Sample Preservation and Storage
Sampling QA/QC Procedures.
Sampling Methods And Equipment
Your WAP must describe the appropriate sampling method that will be used to obtain samples of
wastes destined for management at the facility. Table 4-27 is provided as an example of the type and
content of information you may choose to provide for sampling methods and equipment.
B.
Sample Preservation And Storage
We will not present site-specific information for the sampling preservation and storage requirements
since this information was covered extensively in Section 2.3. You will want to provide similar information in your WAP.
4-68
Sample WAP # 5 - Landfill
C.
Sampling QA/QC Procedures
All sampling conducted for the purpose of characterizing wastes managed by Rottaway Landfill
will use appropriate QA/QC procedures, including chain-of-custody from sample collection
through delivery to the analytical laboratory, and compatible storage containers. Additionally,
Rottaway Landfill will limit the number of personnel who perform sampling to two individuals to
ensure the highest levels of consistency and accuracy. Both individuals receive annual training
in the proper use of sampling and analysis equipment.
V.
SELECTING A LABORATORY AND LABORATORY TESTING AND ANALYTICAL
METHODS
A.
Selecting A Laboratory
This section should discuss the criteria you have used to select a laboratory. For example:
We have selected Buchanan Laboratory to perform all of the detailed quantitative chemical
analyses specified in our WAP. In particular, this laboratory has:
•
•
•
B.
A comprehensive QA/QC program
Technical analytical expertise
An effective information system.
Selecting Testing And Analytical Methods
The selection of analytical testing methods for the wastes received by Rottaway Landfill was
based on the following considerations:
•
•
•
•
VI.
Physical state of the wastes
Analytes of interest
Required detection limits
Information requirements (e.g., verify compliance with LDR treatment
standards).
WASTE RE-EVALUATION
The selected re-evaluation or testing frequency for wastes accepted at a landfill should be established
for all sampling activities associated with:
•
•
•
Pre-acceptance procedures
Waste acceptance procedures
Waste handling at the site.
The RCRA permit application and permit must specify the frequency for each sampling parameter
specified. The frequency criteria may be provided with other information in the permit (see Table 426). Refer to Part Two, Section 2.5, of this guidance manual for assistance.
4-69
FIGURE 4-15
Rottaway Landfill, Inc.
Facility Layout *
CELL A
(Area G)
CELL C
CONTAINER STORAGE
(Areas C AND D)
(Area H)
ACCESS
ROAD
(Area F)
CELL B
CONTAINER STORAGE
(Area E)
Laboratory
(Area I)
TRUCK
STAGING
AREA
(Area B)
OFFICE
CELL D
Incompatibles
Storage
(Area K)
Temporary Drum
Storage Area (Area J)
Main Gate
(Area A)
4-70
FIGURE 4-16
Rottaway Landfill, Inc.
Layout Of Each Landfill Cell
t
ee
5f
2
25
fee
t
Active Cell
4-71
4-71
TABLE 4-24
Rottaway Landfill, Inc.
Identification/EPA Classification Of Hazardous Wastes Managed At Rottaway Landfill
1
2
3
4
5
6
7
CHEMICAL
ANALYSIS 1
WASTE
GENERATOR
NAME, WASTE
PROFILE #
8
TREATMENT
LDR
PROCESS
GENERATING
THE WASTE
4-72
Sparky
Incineration
WPN 1003 4
Incineration
(ash)
Thompson
Manufacturing
WPN 2806 4
Solidification of
paint and
electroplating
WWT plant
sludges
BASIS FOR
HAZARD
CLASSIFICATION
EPA
WASTE
CODE
PHYSICAL
STATE OF
WASTES
Process
Knowledge/
Testing
F002,
F003
Solid
Process
Knowledge/
Testing
F006
Solid
DESIGNATED
STAGING AREA
ON SITE
Area G
Cell B 5
Area F
Cell A 5
2
Waste
Received
WW or NWW
Trichlorofluoromethane 2.0 mg/kg
Acetone 10 mg/kg
NWW
CN (Total) 15 mg/kg
CN (Amenable)
0.2 mg/kg
Cd 0.03 mg/l
Cr 1.5 mg/l
Pb 0.35 mg/l
Ni 0.15 mg/l
Ag <DL6
NWW
Treatment
Standard 3
33 mg/kg
160 mg/kg
CN (Total)
590 mg/kg
CN (Amenable)
30 mg/kg
Cd .066 mg/l
Cr 5.2 mg/l
Pb 0.51 mg/l
Ni 0.32 mg/l
Ag .072 mg/l
1
Metal values are reported for the TCLP extract in mg/l. All other values are reported as total waste analysis in mg/kg.
2 Provided by the generator/certification received from generator.
3 The EPA treatment standard or alternative will be specified. This is the standard that must be achieved, per LDR, (if applicable) or wastes will be rejected. The
values for the metals are expressed as the concentration in the TCLP extract in mg/l. All other values are expressed as the total waste analysis in mg/kg.
4 WPN = Waste Profile Number
5 Corresponds to Figure 4-15.
6 DL = Detection Limit (0.01 mg/l)
.
FIGURE 4-17
Rottaway Landfill, Inc.
Pre-Acceptance Procedures
Pre-Acceptance Criteria
G
E
N
E
R
A
T
O
R
A
C
T
I
V
I
T
I
E
S
Will landfill of this waste cause
operation problems?
GENERATOR
CONTACTS FACILITY
Is waste acceptable in the facility
permit?
WASTE PROFILE IS
SUBMITTED
Is the waste reactive or does it
require special handling?
Do wastes meet LDR treatment
standards?
REPRESENTATIVE
SAMPLE IS SUBMITTED
Sample is analyzed and compared
to waste profile sheet data.
Discrepancy Exists
No Discrepancies
(Waste is Approved)
Contact Generator
Determine Proper Waste
Handling Procedures at
Landfill
Resolve Discrepancy
No Resolution:
Reject Waste
Shipment
Complete Waste Profile,
Assign Internal Waste
Registration #
Schedule Waste
Shipment
4-73
4-73
Designate Compatible
Storage Area for Containers
Notify On-Site Laboratory
of Waste
Analysis/Fingerprint
Analysis Procedures
Fill Out Waste
Acceptance Sheet
(Specific Waste Sampling
Materials and Equipment)
FIGURE 4-18
Rottaway Landfill, Inc.
Incoming Waste Shipment Procedures (Waste Acceptance Procedures)
Waste Shipment Arrives
Compare Shipment Externally
to Its Manifest and LDR
Notification/Certification
Visually Inspect Shipment
and Compare to Waste
Profile Description
Discrepancy*
Contact
Generator
Fill out Waste Receipt
Inspection Report
Sample Waste
Lab Packs Auditing
Analyze Waste Parameters
Evaluate Analytical Data
1
Random Sampling for PCB's
and Dioxins
Discrepancy
Contact Generator
Evaluate Analytical Data
Recharacterize Waste
Accept Waste Shipment
Store Waste in Designated
Storage Area
1
If discrepancy is found, the next shipment from this generator is subject to increased level of analysis.
4-74
4-74
Reject Waste
Shipment
FIGURE 4-19
Procedures For Designating Landfill Storage Units (Cells)
STORAGE
EVALUATION
*
•
•
•
INFORMATION
REGARDING EXISTING
STORAGE CONTENTS
COMPATIBLE
INFORMATION
REGARDING PERMIT
OPERATING
PROCEDURES
INFORMATION
REGARDING
CONSTRUCTION OF
STORAGE MATERIALS
INCOMPATIBLE
ANALYSES
AS NECESSARY
e.g., reactivity 1
SELECT ANOTHER
STORAGE UNIT
1
APPROPRIATE
STORAGE
UNIT
REJECT
Your WAP will designate the types of analysis or parameters that will be necessary to confirm or
deny the storage of wastes in designated storage units.
4-75
TABLE 4-25
Rottaway Landfill, Inc.
Fingerprint Analysis Used To Sample Incoming Wastes
CHEMICAL PARAMETERS
PHYSICAL PARAMETERS
Cyanide*
PCBs*
% CI*
% F*
% Br*
% S*
Organic Parameters**
(Prohibited Part 261,
Appendix VIII
Constituents)
Inorganic
Parameters (TCLP
metals)**
% Water*
Radioactivity*
Specific Gravity*
VISUAL PARAMETERS
Color*
Phases*
Viscosity*
Turbidity*
Layers*
* Checked each time the waste is shipped (other parameters are tested only when initial or updated
representative samples are provided.
** Unique parameters will be selected for each waste stream and designated in the Waste Profile
Sheet.
4-76
4-76
TABLE 4-26
Rottaway Landfill, Inc.
Selected Parameters: Rationale, Criteria, And Special Consideration
WASTE
PARAMETERS
CRITERIA
RATIONALE
FREQUENCY
SPECIAL
CONSIDERATIONS
F002
Ash
trichlorofluoromethane
33 mg/kg
To determine if
above LDR
treatment
standards
Each batch
Must use total waste
analysis to
demonstrate
compliance
F003
Ash
acetone
160 mg/kg
To determine if
above LDR
treatment
standards
Each batch
Must use total waste
analysis to
demonstrate
compliance
All wastes
PCBs
<50 mg/kg
To determine
presence of
PCBs
Each batch
PCBs above 50 mg/kg
not acceptable in the
facility's permit
F006
Slag
Reactivity
<150 mg/kg
of CN
To ensure that no
significant
concentrations of
CN are released
Each batch
Reactive wastes will
not be land disposed
F006
Slag
Cd
Cr
Ni
Pb
Ag
CN (Total)
CN (Amenable)
Cd .066 mg/l
Cr 5.2 mg/l
Ni .32 mg/l
Pb .51 mg/l
Ag .072 mg/l
CN (Total)
590 mg/kg
CN
(Amenable)
30 mg/kg
To determine if
concentration
exceed LDR
treatment
standards
Each batch
Must meet treatment
standards in both
268.41 - 268.43
1
Metal values are reported as the concentration in the TCLP extract in mg/l. All other values are
reported for the total waste analysis in mg/kg.
4-77
4-77
TABLE 4-27
Rottaway Landfill, Inc.
Sampling Methods And Equipment
WASTE
MATERIAL
SAMPLING
METHOD
SAMPLING
EQUIPMENT
SAMPLING
STRATEGY
Fly ash-like material
ASTM D 2234-76 or
ASTM E 300 a
Tube sampler d, trier,
auger, scoop, or shovel
Simple random
(grab)
Containerized liquids
(e.g., tank, drums) c
SW-846 b or
ASTM E 300 a
Coliwasa/tube sampler d,
weighted bottle, bomb, or
tank sampling ports
Simple random
(grab)
a --
b --
c --
d --
a
American Society for Testing and Materials, 1982. Annual Book of ASTM Standards, Philadelphia,
PA, or most recent edition.
Test Methods for Evaluating Solid Waste, 1980, SW-846, 2nd Edition, U.S. Environmental
Protection Agency, Office of Water and Waste Management, Washington, DC, or most recent
edition.
The specific equipment is dependent on the type of container. See SW-846 for specific examples.
See also Section 2.2.
Personal Protection and Safety Training Manual (Cincinnati, Ohio: U.S. Environmental Protection
Agency, National Training and Operational Technology Center, 1981), pp. 3-1 and 3-4.
4-78
4-78
APPENDIX A
HAZARDOUS WASTE IDENTIFICATION
EPA was granted the authority to develop criteria for the identification of hazardous wastes under
Section 3001 of RCRA. Under Section 1004 of RCRA, a hazardous waste is defined as a solid waste,
or a combination of solid wastes which, because of its quantity, concentration, or physical, chemical, or
infectious characteristics, may cause, or significantly contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed,
or otherwise managed. The regulatory definition of a hazardous waste is found in 40 CFR §261.3.
Solid wastes are defined by regulation as hazardous wastes in two ways. First, solid wastes are hazardous wastes if EPA lists them as hazardous wastes; the lists of hazardous wastes are found in 40 CFR
Part 261, Subpart D. EPA lists wastes based on criteria in 40 CFR §261.11. Wastes listed by EPA as
hazardous contain hazardous constituents, are acutely hazardous, and/or exhibit the characteristics of
ignitability, corrosivity, reactivity, or toxicity. Second, EPA identifies the characteristics of a hazardous
waste based on criteria in 40 CFR §261.10. Accordingly, solid wastes are hazardous if they exhibit any
of the following four characteristics of a hazardous waste: ignitability, corrosivity, reactivity, or toxicity
(based on the results of the TCLP). Descriptions of these hazardous waste characteristics are found in
40 CFR Part 261, Subpart C. Exclusions to the regulatory definitions of solid waste and hazardous
waste are found in 40 CFR §261.4.
[Note: EPA is in the process of issuing new rules on the definition of hazardous waste. Regardless of changes in the rules, the format, content, procedures, and implementation of a WAP will
not change.]
Generators must conduct a hazardous waste determination according to the hierarchy specified in 40
CFR §262.11. Figure A-1 can be used to assist in making this hazardous waste determination, and can
serve as a roadmap when reviewing the rest of Appendix A. Persons who generate a solid waste first
must determine if the solid waste is excluded from the definition of hazardous waste under the provisions of 40 CFR §261.4. If the waste is not excluded, the generator must determine if it is listed as a
hazardous waste; if the waste is not listed, or for the purposes of complying with the LDR requirements
in 40 CFR Part 268, the generator must determine if the waste exhibits a characteristic of a hazardous
waste, either by testing the waste or by utilizing knowledge about the process or materials used to
generate the waste.
Listing Determination
Once the generator determines that a solid waste is not excluded, then he/she must determine if the
waste meets one or more of the hazardous waste listing descriptions. The hazardous waste lists include
wastes from nonspecific sources (termed “F-listed wastes,” after the F prefix in the hazardous waste
codes); these wastes include spent solvents, electroplating wastes, and dioxin-bearing wastes. The
hazardous waste listings also include wastes from specific sources (i.e., K-listed wastes), including
wastes from wood preserving operations, organic and inorganic chemical production, pesticide formulation, explosives manufacturing, petroleum refining, iron and steel production, pharmaceutical manufacturing, and the lead, zinc, copper, and aluminum industries. The third group of hazardous waste listings
include discarded unused commercial chemical products, off-specification products, and spill residues
of such products (i.e., P- and U-listed wastes).
A-1
FIGURE A-1
Hazardous Waste Identification
No
Is the material a
solid waste under 40
CFR §261.2?
Not a Hazardous Waste
Yes
Is the waste
excluded under
40 CFR §261.4?
Yes
Not a Hazardous Waste
No
Listed
No
Hazardous
Waste
• Has the waste been delisted in
accordance with 40 CFR §§260.20 and
Yes
260.22? or
• Does the mixture or derived-from residue
qualify for any of the exclusions from the
mixture and derived-from rules in 40 CFR
§261.3?
Yes,
Not a Listed
Hazardous Waste
No
Does the waste exhibit
a characteristic of
hazardous waste in 40
CFR Part 261, Subpart
C?*
For purposes of the Land Disposal
Restrictions program of 40 CFR Part
268, does the listed waste exhibit a
characteristic of hazardous waste in 40
CFR Part 261, Subpart C
Yes,
Listed and
Characteristic
Hazardous Waste
• Does the waste meet any of the listing
descriptions in 40 CFR Part 261, Subpart D? or
• Is the waste mixed with a listed hazardous
waste? or
• Is the waste derived from the treatment, storage,
or disposal of a listed hazardous waste?
No,
Listed
Hazardous
Waste
No
Not a Hazardous
Waste
Yes
Characteristic
Hazardous
Waste
* Note exception for mixtures of characteristic wastes and mining/mineral processing wastes in 40 CFR §261.3(a)(2)(i).
A-2
A-2
The hazardous waste listings also apply to certain mixtures of solid wastes. Under the “mixture rule”
in 40 CFR §§261.3(a)(2)(iii) and (iv), mixtures of listed hazardous wastes and solid nonhazardous
wastes are defined as hazardous wastes and retain their listing designations unless the hazardous waste
in the mixture is listed solely based on a particular characteristic (that is, ignitability [I], corrosivity
[C], reactivity [R], toxicity [E]) and the mixture no longer exhibits any of these hazardous waste
characteristics. For example, a mixture of a spent methylene chloride formulation (listed as F002
because of its hazardous constituents) and used oil would be defined as a hazardous waste and be
designated as F002 whether or not the mixture exhibited a hazardous waste characteristic. The mixture remains a hazardous waste unless the generator successfully petitions to delist the waste according
to procedures outlined in 40 CFR §260.22.
The hazardous waste listings also apply to solid wastes that are derived from the treatment, storage, or
disposal of a listed hazardous waste. The “derived-from rule” (40 CFR §261.3(c)(2)) defines residual
solid wastes derived from the treatment, storage, or disposal of a listed hazardous waste as a hazardous
waste. Examples of wastes defined as hazardous through the derived-from rule include ash resulting
from the incineration of off-specification toluene (U220), and leachate resulting from the disposal of
API separator sludge from the petroleum refining industry (K051) in a landfill. As with the mixture
rule, a generator may petition EPA to delist a waste that is derived from a listed waste.
EPA also regulates mixtures of hazardous wastes and other materials that are not solid wastes. The
“contained-policy” states that materials containing a listed hazardous waste must be managed as
hazardous wastes until the listed waste can be removed from the mixture. This provision mainly
applies to mixtures of listed hazardous wastes and environmental media (e.g., contaminated ground
water, contaminated soil) that cannot be regulated by the mixture rule. An example of a waste regulated under the contained-in policy is soil contaminated with cyanides that has been excavated from
under a tank that contains spent cyanide plating bath solutions from an electroplating operation
(F007); this soil would be managed as F007.
Characteristics Determination
A solid waste that does not meet a listing for a hazardous waste must be evaluated by the generator to
determine if it exhibits a characteristic of a hazardous waste. A generator must evaluate such wastes
to determine if they exhibit any of the four characteristics of a hazardous waste: ignitability,
corrosivity, reactivity, and toxicity. This evaluation involves testing the waste or using knowledge of
the process or materials used to produce the waste.
A waste is defined as ignitable according to a definition in 40 CFR §261.21. A waste is ignitable if it
is a liquid and its flash point is less than 140o F (60o C). EPA Test Method 1010 (Pensky-Martens
Closed Cup Method), EPA Test Method 1020 (Setaflash Closed Cup Method), or equivalent methods
may be used to test for ignitability. A waste may also be defined as ignitable if it is an oxidizer or an
ignitable compressed gas as defined in Department of Transportation (DOT) regulations in 40 CFR
Part 173, or if it has the potential to ignite under standard temperature and pressure and burn persistently and vigorously once ignited. Wastes that are ignitable are classified as EPA Hazardous Code
D001. Examples of ignitable wastes are certain spent solvents (e.g., mineral spirits) and off-specification jet fuels.
The characteristic of corrosivity is described in 40 CFR §261.22. A waste is corrosive if it is aqueous
(defined as amenable to pH measurement) and its pH is less than or equal to 2 or greater than or equal
A-3
to 12.5. The tests used for this pH determination are EPA Test Method 9040 (pH Electrometric Measurement), EPA Test Method 9041 (pH Paper Method), or an equivalent method. A waste is also
corrosive if it is a liquid and it corrodes steel at a rate of more than 0.25 inches per year under conditions specified in EPA Test Method 1110. Corrosive wastes are designated as EPA Hazardous Waste
Code D002. Corrosive wastes include spent sulfuric acid and concentrated waste sodium hydroxide
solutions that have not been neutralized.
A waste exhibits the characteristic of reactivity if it meets any of the criteria in 40 CFR §261.23. Only
the reactivity criterion for cyanide- and sulfide-bearing wastes, however, has an established test
method. EPA guidance provides that a waste is considered reactive under 40 CFR §261.23(a)(5) if it
releases more than 250 mg of hydrogen cyanide per kg of waste or 500 mg of hydrogen sulfide per kg
of waste as measured by the test methods in SW-846 Sections 7.3.3.2 and 7.3.4.2, respectively. Wastes
that exhibit the characteristic of reactivity are classified as EPA Hazardous Wastes Code D003.
The final characteristic of a hazardous waste is the toxicity characteristic (TC). Generators who opt
to test their waste for this characteristic must develop an extract of the waste according to the Toxicity
Characteristic Leaching Procedure (TCLP - EPA Test Method 1311) found in Appendix II to 40 CFR
Part 261. The extract is then subsequently analyzed using one or more of several methods listed
below. The results of the analysis are compared to regulatory thresholds for 40 constituents in 40 CFR
§261.24. Test methods in this step may include the following:
•
EPA Test Methods 3010 and 6010 - for arsenic, barium, cadmium, chromium, lead,
silver, and selenium
•
EPA Test Method 7470 - mercury
•
EPA Test Methods 3510 and 8080 - pesticides
•
EPA Test Method 8240 - for volatile organics
•
EPA Methods 3510 and 8270 - semivolatile organics
•
EPA Test Method 8150 - herbicides.
If the extract from the TCLP procedure contains levels of any of the 40 constituents at or above regulatory thresholds, the waste is considered a hazardous waste. Wastes that exhibit the toxicity characteristic are classified as EPA Hazardous Waste Codes D004 through D043. Examples of wastes that may
exhibit the characteristic of toxicity include petroleum wastes, wastes from organic chemical manufacturing, and pesticide and herbicide wastes.
Certain states may also have requirements for identifying hazardous wastes in addition to those described above. States authorized to implement the RCRA or HSWA programs under Section 3006 of
RCRA may promulgate regulations that are more stringent or broader in scope than federal regulations.
For example, certain states have broadened the scope of the hazardous waste listings by specifically
listing used oil as a hazardous waste. Some states also regulate hazardous wastes based on total (versus extract) waste analysis of individual hazardous constituents.
A-4
APPENDIX B
REGULATORY SUMMARY
This appendix presents a brief summary of relevant RCRA regulatory requirements. It is not meant to be a
complete or detailed description of all applicable RCRA regulations. For more information concerning
specific requirements, consult the Federal Registers cited herein and the Code of Federal Regulations, Title
40 Parts 261, 264, 265, 266, and 268.
Land Disposal Restrictions (LDR) (40 CFR Part 268)
The 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA prohibit the land disposal of specific
groups of hazardous waste, unless it has been determined that there will be no migration of the hazardous
constituents. The amendments also required EPA to establish treatment standards for all listed and characteristic wastes, expressed as concentration levels or methods of treatment, that will reduce their toxicity and
make them safe for land disposal. These treatment standards are found in Part 268, Subpart D. LDRs apply
to all generators and transporters of hazardous waste as well as to owners and operators of treatment, storage, and disposal facilities (TSDFs).
Generators must determine whether their waste is subject to LDRs for each hazardous waste at the point of
generation. HSWA requires that both listed and characteristic determinations be made for each waste. The
generator can make this determination based on knowledge of the waste, by conducting a total waste analysis, or by testing the waste extract. If a generator determines the waste is prohibited from land disposal and
elects to treat the waste on site (in accumulation tanks, containers, or containment buildings regulated under
40 CFR §262.34), a written waste analysis plan (WAP) must be developed to describe the procedures the
generator will carry out to comply with the treatment standards. The plan must be kept on site in the
generator’s records and it must be submitted to the Regional Administrator. Although no specific criteria are
established for generators developing a WAP in accordance with 40 CFR §268.7(a)(4), the plan should be
written in accordance with the procedures prescribed in this manual (i.e., describe the physical and chemical
analysis that will be conducted on a representative sample of the waste(s) being treated, and specifically
describe the frequency of testing). WAPs are not required from generators who are treating for purposes
other than meeting LDR treatment standards. The generator of the waste must provide notification to any
facility receiving their waste as to the status of the waste with respect to LDR. If the waste meets the applicable LDR treatment standard, the generator must provide certification to the receiving facility.
Treatment/storage facilities are responsible for including in their WAP (40 CFR §§264.13/265.13) procedures used to corroborate that correct treatment standards have been selected for incoming wastes and
provisions for testing the waste to verify that it meets the LDR treatment standard(s). These facilities will
receive the generators’ certification and any available waste analysis data provided by the generator (40 CFR
§§264.73, 265.73). However, upon subsequent management of the waste, the treatment/storage facility, like
the generator who ships directly to a disposal facility, must certify to the disposal facility that the waste
meets the applicable treatment standards.
The disposal facility receives certifications that the waste meets LDR treatment standards from generators
and treatment/storage facilities. The results of waste analysis or other information on the waste’s properties
should also be provided by generators or treaters of the waste. The disposal facility must conduct sampling
and analysis of incoming wastes to verify that wastes meet the relevant treatment standards for the specific
waste. The procedures for waste sampling and analysis, including the frequency of testing, must be documented in the facility’s WAP.
B-1
Further discussion of LDRs is available in “Land Disposal Restrictions: Summary of Requirements,” February 1991, OSWER 9934.0-1A.
Boilers And Industrial Furnaces (40 CFR Part 266, Subpart H)
Boilers and Industrial Furnaces (BIF) that burn hazardous waste as fuel for energy or materials
recovery, have previously been exempt from obtaining RCRA operating permits. A new rule,
finalized on February 21, 1991, regulates the burning of hazardous waste in boilers and industrial
furnaces. This rule imposes new operating and regulatory standards on BIFs. Many of the RCRA
standards currently applied only to incinerators now also apply to BIFs burning hazardous waste as
fuel.
The regulatory standards for BIFs became effective on August 21, 1991, and apply to cement kilns;
lime kilns; aggregate kilns; smelting, melting, and refining furnaces; and halogen acid furnaces.
The new BIF rule regulates all industrial furnaces processing hazardous waste fuel for energy,
material recovery, or destruction except for furnaces that process hazardous waste for metals reclamation (recycling) or those burning small quantities of wastes as fuel.
Under the new rule, EPA requires some facility owners and operators to obtain operating permits by
imposing similar operating conditions as those required of incinerator facilities. The rule further
requires facilities to operate only under conditions specified in the permit and to comply with standards for controlling and monitoring the amount of pollutants released to the atmosphere from
burning activities.
As specified in 40 CFR Part 266 (Subpart H), facility owners and operators must demonstrate to
EPA that furnaces can be operated without releasing unacceptable amounts of particulate materials
(dusts), toxic metals, hydrochloric acid, carbon monoxide, chlorine, hydrocarbons, and dioxin/furans
into the atmosphere. In addition, waste fuels must be sampled and analyzed prior to burning. Prior
to obtaining a permit, the owner/operator is required to perform an analysis of the hazardous waste to
be managed to identify the presence of the listed hazardous chemical constituents (Appendix VIII of
40 CFR Part 261). The results of the analyses are used by the permit writer to establish operating
conditions for the facility. Throughout normal operation, the facility owner/operator must conduct
sampling and analysis to ensure that the hazardous waste, and other fuels burned in the boiler or
industrial furnace are within specific limits established in the permit for the facility. A WAP must
be developed that describes how samples of waste fuel are collected and analyzed to determine
physical and chemical characteristics of the fuel. The WAP must include the information specified in
40 CFR §264.13.
To qualify for interim status under the new rule, owners/operators of “existing” BIF facilities must
have submitted a RCRA Part A application and certificate of precompliance by August 21, 1991. A
certificate of compliance, including air emissions testing results, was required by August 21, 1992.
During interim status, BIFs must meet the interim status standards for boilers contained in 40 CFR
§266.103.
B-2
Tank Systems (40 CFR Parts 264/265, Subpart J)
On July 14, 1986, EPA established operating standards for facility owners and operators that accumulate, store or treat hazardous waste in tanks. These regulations detailed in 40 CFR Parts 264/265
Subpart J, establish technical standards and operating procedures for tank systems that include requirements for installation, leak testing and detection, corrosion protection, structural integrity,
secondary containment, responses to leaks in the environment, closure and post closure care. Separate standards are established in 40 CFR Part 280 for tanks storing petroleum and other hazardous
substances that are not RCRA hazardous wastes.
If you operate a tank system that is used to manage hazardous waste, you must comply with the
general standards for treatment, storage, and disposal facilities, including preparation of a WAP.
Miscellaneous Units (40 CFR Part 264, Subpart X)
On December 21, 1987, EPA established standards for locating, designing, constructing, operating,
and maintaining miscellaneous units that are used to store, treat, or dispose of hazardous waste.
These units include geologic repositories, deactivated missile silos, thermal treatment units, open
burning/open detonation units for explosive wastes, some chemical, physical, and biological treatment units and any other units not previously regulated in 40 CFR Part 264 (e.g., containers, tanks,
surface impoundments, waste piles, land treatment units, landfills, incinerators, underground injection wells, and research development and demonstration projects). Facility owners and operators of
treatment storage and disposal facilities must comply with these requirements if they are managing
wastes in miscellaneous units.
The regulation requires facility owners/operators to obtain operating permits and meet various environmental performance criteria. These criteria were established to prevent the release and migration
of wastes from these units from adversely affecting human health and the environment. The regulations require owners/operators to submit detailed information on the environmental features of the
facility and waste characteristics as part of their permit application.
Other standards of this regulation require owners and operators to demonstrate compliance with the
TSDF standards specified in 40 CFR Part 264 Subparts A-H, including monitoring, analyses, inspection, response and corrective action.
Permits issued by EPA under this regulation require owners and operators of miscellaneous units to
perform general waste analysis, as outlined in 40 CFR §264.13 and to develop a WAP.
Toxicity Characteristic And TCLP (40 CFR Part 261, Subpart C)
Waste defined as hazardous, may be found to exhibit certain hazardous characteristics or it may be
designated as a listed waste based on its origin. The four characteristics that may define a waste as
hazardous are ignitability, corrosivity, reactivity, and, until recently, Extraction Procedure (EP)
toxicity. The Extraction Procedure Toxicity Test (EP TOX Test) measures the potential for the toxic
constituents in the waste to leach and migrate to surrounding media. The EP TOX Test was used by
B-3
EPA to measure the potential for landfilled wastes to present a public health hazard and, thus, be
classified as a hazardous waste.
HSWA directed EPA to examine and revise the EP TOX Test established under RCRA. On March
29, 1990, EPA promulgated the Toxicity Characteristic (TC) rule which replaced the EP TOX Test
with the Toxicity Characteristic Leaching Procedure (TCLP), identified 25 additional organic hazardous waste constituents of concern, and established regulatory threshold levels for these organic
chemicals (55 FR 11798). The modified and improved leaching test and the addition of 25 more
constituents of concern greatly increased the amounts of wastes considered hazardous.
Air Emissions From TSDFs (40 CFR Parts 264/265, Subparts AA And BB)
The organic air emission regulations establish standards to minimize the release of organic emissions to the atmosphere from process vents and equipment. These requirements apply to TSDF
hazardous waste management (and recycling) units that manage waste with organic concentrations
above specificied levels. Facility owners/operators are required to identify and meet specific technical requirements for all process vents associated with distillation, fractionation, thin-film evaporation, solvent extraction, and stripping processes that manage wastes with a 10-ppmw (ppm by
weight) or greater total organics concentration on a time-weighted annual average basis.1 Additionally, TSDFs with equipment (e.g., pumps, valves, compressors) that contains or contacts hazardous
wastes exceeding a total organic concentration of 10 percent or greater must meet emission control
and monitoring standards. Specific equipment subject to these regulatory provisions include
pumps, compressors, valves, pressure relief devices, flanges, or other connectors.
A determination of the applicability of the organic air emissions standards is made based on direct
measurement of the organic concentration of the waste using specified analytical procedures, or
knowledge of the process from which it was produced The methods used and the results of the
waste determination must be documented in the WAP for the facility.
For facilities subject to the process vent and equipment leak standards that exceed applicable emission criteria, control devices or techniques must be implemented to minimize the release of organic
vapors. These emission controls must comply with applicable design, monitoring, testing and
recordkeeping requirements established under 40 CFR Parts 264/265 Subparts AA and BB.
The implementation schedule for the organic emissions standards is dependent upon your existing
facility status. Facilities that are newly permitted or obtain interim status after the December 21,
1991, effective date of the rule must comply with the organic air emissions standards immediately.
Interim status facilities in operation at the time of the rule’s effective date, however, had an additional 18 months to install and operate control devices. Finally, facilities that have been issued a
final permit prior to December 21, 1991, are not required to comply with the new standards until
such time that the permit is reviewed or reissued.
140
CFR §§264/5.1034(d)
B-4
Prohibition Of Liquids In Landfills (40 CFR Part 264/265, Subpart N)
On July 15, 1985, EPA amended the standards for permitted landfills and interim status landfills to
ban the placement of bulk or non-containerized, liquid hazardous or non-hazardous waste, or hazardous waste containing free liquids in any landfill. EPA interprets the ban on “placement” to
include, but not be limited to: (1) placing bulk liquids into a landfill cell where the liquids are
solidified and then transferred to another cell, and (2) placing treated bulk liquids still in liquid form
into a landfill prior to solidification. For non-hazardous liquids, an exemption exists if the owner/
operator can demonstrate that: (1) the only available alternative for these non-hazardous liquids is a
landfill or unlined surface impoundment, which already contains hazardous waste, and (2) the
disposal of the non-hazardous liquids in the landfill will not present a risk of contamination to any
underground source of drinking water.
Hazardous and nonhazardous liquids may be placed into landfills after being chemically and physically treated so that free liquids are no longer present in the waste. If waste is mixed with a sorbent
to remove free liquids, the sorbent must be nonbiodegradable. Examples of such sorbents are
provided in 40 CFR §§264.314(e) and 265.314(f). If wastes are to be treated with sorbents which
are not specifically listed, the sorbent must be tested using specified ASTM methods to ensure that it
is nonbiodegradable.
Landfills, regulated under RCRA as treatment, storage, and disposal facilities, must perform
general waste analysis, as outlined in 40 CFR Part 264 and develop a WAP. The waste analysis
must demonstrate the absence or presence of free liquids in either containerized or bulk waste, using
Method 9095 (Paint Filter Liquids Test) as described in “Test Methods for Evaluating Solid Wastes,
Physical/Chemical Methods” (SW-846) or another equivalent test method. Waste analysis must
also be used to determine whether containerized wastes have been mixed with biodegradable sorbents.
B-5
Appendix C
Table C-1
Waste Analysis Data Flow Responsibilities
Notification
2
1
Certification
How
Certifies
Often?
to Whom?
Notifies
Whom?
How
Often?
Generator manages a restricted waste that
does not meet the treatment
standards/prohibition levels; sends it off site for
storage or treatment (40 CFR §268.7(a)(1))
Treatment,
storage, or
recycling facility
With each
shipment
• EPA hazardous waste code(s)
• Corresponding concentration-based or
technology-based treatment standards, or
prohibition level
• Manifest number
• Waste analysis data
N/A
N/A
Generator manages a restricted waste, and
determines that the waste can be land
disposed without further treatment (40 CFR
§268.7(a)(2))
Storage, recycling,
or disposal facility
With each
shipment
• EPA hazardous waste code(s)
• Corresponding concentration-based or
technology-based treatment standards, or
prohibition level
• Manifest number
• Waste analysis data
TSD facility
With each
shipment
With each
shipment
• EPA hazardous waste code(s)
• Corresponding concentration-based or
technology-based treatment standards, or
prohibition level
• Manifest number
• Waste analysis data
• The date the waste is subject to the prohibitions
Statement that waste is not prohibited from land
• disposal
N/A
N/A
N/A
N/A
Scenario
C-1
Generator's waste is subject to a case-by-case
extension under §268.5, exemption under
§268.6, or a nationwide variance under (40
CFR §268.7(a)(3))
Facility receiving
waste (MTR unit)
Recycling facility
Small quantity generator (100-1,000 kg/month)
subject to tolling agreement pursuant to 40
CFR §262.20(e), (40 CFR §268.7(a)(10)
1
With initial
shipment
A full description of the notification responsibilities is documented in 40 CFR §268.7
requirements are presented in 40 CFR §268.7
3N/A denotes not applicable
2Certifications
Summary of Notification Responsibilities
EPA hazardous waste code(s)
• Corresponding concentration-based or
technology-based treatment standards, or
prohibition level
• Manifest number
• Waste analysis data
3
Appendix C
Table C-1
Waste Analysis Data Flow Responsibilities (continued)
1
2
Notification
Scenario
Generator sending lab pack containing
restricted wastes, and is applying alternate lab
pack standard in 40 CFR §268.42, Appendix
IV or V (40 CFR §268.7(a)(8) and (a)(9))
Notifies
Whom?
How
Often?
Treatment or
storage facility
With each
shipment
C-2
Generator or TSD facility sending characteristic
waste that has been rendered non-hazardous
to a subtitle D land disposal facility (40 CFR
§268.9)
1
Land disposal
facility
Regional
Administrator or
authorized State
With each
shipment
One time
4
A full description of the notification responsibilities is documented in 40 CFR §268.7
are presented in 40 CFR §268.7
2
Certifications requirements
3
N/A denotes not applicable
4
•
•
•
•
All EPA hazardous waste codes
Five letter technology code: INCIN
Manifest number
Waste analysis data
Treatment or
storage facility
With each
shipment
Must meet same notification and certification requirements applicable to generators
TSD facilities sending restricted waste
off-site for additional treatment or storage (40
CFR §268.7(b)(6))
Treatment facilities sending restricted wastes
off site to land disposal facilities (LDFs) (40
CFR §268.7(b)(4))
Summary of Notification Responsibilities
Certification
How
Certifies
to Whom?
Often?
This requirement reflects changes in the LDR Phase I Rule (57 FR 37271, August 18, 1992)
• EPA hazardous waste code(s)
• Corresponding concentration-based or
technology-based treatment standards, or
prohibition level
• Manifest number
• Waste analysis data
• Name and address of subtitle D facility
• Description of waste, as generated
• Concentration-based or technology-based
treatment standards or prohibition level
applicable to waste at time of generation
Land disposal
facility
Regional
Administrator
or authorized
State
With each
shipment
One time
4
APPENDIX D
REGULATORY CITATIONS FOR CONDUCTING WASTE ANALYSIS
40 CFR §264.13 General Waste Analysis
The following is an excerpt from 40 CFR 264 that contains the regulatory requirements for
waste analysis plans for hazardous waste treatment, storage, and disposal facilities.
(a)(1) Before an owner or operator treats, stores, or disposes of any hazardous wastes,
or non-hazardous wastes if applicable under §264.113(d), he must obtain a detailed
chemical and physical analysis of a representative sample of the wastes. At a minimum,
the analysis must contain all the information which must be known to treat, store, or
dispose of the waste in accordance with this part and part 268 of this chapter.
(2)
The analysis may include data developed under Part 261 of this chapter, and
existing published or documented data on the hazardous waste or on hazardous waste
generated from similar processes.
[Comment: For example, the facility’s records of analyses performed on the waste before
the effective date of these regulations, or studies conducted on hazardous waste generated
from processes similar to that which generated the waste to be managed at the facility,
may be included in the data base required to comply with paragraph (a)(1) of this section.
The owner or operator of an offsite facility may arrange for the generator of the hazardous
waste to supply part of the information required by paragraph (a)(1) of this section, except
as otherwise specified in 40 CFR 268.7(b) and (c). If the generator does not supply the
information, and the owner or operator chooses to accept a hazardous waste, the owner or
operator is responsible for obtaining the information required to comply with this section.]
(3)
The analysis must be repeated as necessary to ensure that it is accurate and up to
date. At a minimum, the analysis must be repeated:
(i)
When the owner or operator is notified, or has reason to believe, that the process
or operation generating the hazardous wastes, or non-hazardous wastes if applicable under
§264.113(d), has changed; and
(ii)
For off-site facilities, when the results of the inspection required in paragraph
(a)(4) of this section indicate that the hazardous waste received at the facility does not
match the waste designated on the accompanying manifest or shipping paper.
(4)
The owner or operator of an offsite facility must inspect and, if necessary,
analyze each hazardous waste movement received at the facility to determine whether it
matches the identity of the waste specified on the accompanying manifest or shipping
paper.
(b)
The owner or operator must develop and follow a written waste analysis plan
which describes the procedures which he will carry out to comply with paragraph (a) of
this section. He must keep this plan at the facility. At a minimum, the plan must specify:
(1)
The parameters for which each hazardous waste, or non-hazardous waste if
applicable under §264.113(d), will be analyzed and the rationale for the section of these
parameters (i.e., how analysis for these parameters will provide sufficient information on
D-1
the waste’s properties to comply with paragraph (a) of this section);
(2)
The test method which will be used to test for these parameters;
(3)
The sampling method which will be used to obtain a representative sample of the
waste to be analyzed. A representative sample may be obtained using either:
(i)
One of the sampling methods described in Appendix I of Part 261 of this chapter;
or
(ii)
An equivalent sampling method.
[Comment: See §260.21 of this chapter for related discussion.]
(4)
The frequency with which the initial analysis of the waste will be reviewed or
repeated to ensure that the analysis is accurate and up to date; and
(5)
For off-site facilities, the waste analyses that hazardous waste generators have
agreed to supply.
(6)
Where applicable, the methods which will be used to meet the additional waste
analysis requirements for specific waste management methods as specified in §§264.17,
264.314, 264.341, 264.1034(d), 264.1063(d), and 268.7 of this chapter.
(7)
For surface impoundments exempted from land disposal restrictions under
§268.4(a), the procedures and schedules for:
(i)
The sampling of impoundment contents;
(ii)
The analysis of test data; and
(iii) The annual removal of residues which are not delisted under §260.22 of this
chapter or which exhibit a characteristic of hazardous waste and either:
(A)
Do not meet applicable treatment standards of Part 268, Subpart D; or
(B)
Where no treatment standards have been established:
(1)
Such residues are prohibited from land disposal under §268.32 or RCRA section
2004(d); or
(2)
Such residues are prohibited from land disposal under §268.33(f).
(c)
For off-site facilities, the waste analysis plan required in paragraph (b) of this
section must also specify the procedures which will be used to inspect and, if necessary,
analyze each movement of hazardous waste received at the facility to ensure that it matches
the identity of the waste designated on the accompanying manifest or shipping paper. At a
minimum, the plan must describe:
(1)
The procedures which will be used to determine the identity of each movement of
waste managed at the facility; and
(2)
The sampling method which will be used to obtain a representative sample of the
waste to be identified, if the identification method includes sampling.
(3)
The procedures that the owner or operator of an off-site landfill receiving containerized hazardous waste will use to determine whether a hazardous waste generator or treater
has added a biodegradable sorbent to the waste in the container.
[Comment: Part 270 of this chapter requires that the waste analysis plan be submitted with
Part B of the permit application.]
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40 CFR §265.13 General Waste Analysis
The following is an excerpt from 40 CFR 265 that contains the regulatory requirements for waste
analysis plans for hazardous waste treatment, storage, and disposal facilities operating under interim
standards.
(a)(1) Before an owner or operator treats, stores, or disposes of any hazardous wastes, or
non-hazardous wastes if applicable under §265.113(d), he must obtain a detailed chemical and
physical analysis of a representative sample of the wastes. At a minimum, the analysis must
contain all the information which must be known to treat, store, or dispose of the waste in
accordance with this part and part 268 of this chapter.
(2)
The analysis may include data developed under Part 261 of this chapter, and existing
published or documented data on the hazardous waste or on waste generated from similar
processes.
[Comment: For example, the facility’s records of analyses performed on the waste before the
effective date of these regulations, or studies conducted on hazardous waste generated from
processes similar to that which generated the waste to be managed at the facility, may be
included in the data base required to comply with paragraph (a)(1) of this section. The owner
or operator of an offsite facility may arrange for the generator of the hazardous waste to supply
part of the information required by paragraph (a)(1) of this section, except as otherwise specified in 40 CFR 268.7(b) and (c). If the generator does not supply the information, and the
owner or operator chooses to accept a hazardous waste, the owner or operator is responsible
for obtaining the information required to comply with this section.]
(3)
The analysis must be repeated as necessary to ensure that it is accurate and up to
date. At a minimum, the analysis must be repeated:
(i)
When the owner or operator is notified, or has reason to believe, that the process or
operation generating the hazardous wastes, or non-hazardous wastes, if applicable under
§265.113(d), has changed; and
(ii)
For off-site facilities, when the results of the inspection required in paragraph (a)(4)
of this section indicate that the hazardous waste received at the facility does not match the
waste designated on the accompanying manifest or shipping paper.
(4)
The owner or operator of an offsite facility must inspect and, if necessary, analyze
each hazardous waste movement received at the facility to determine whether it matches the
identity of the waste specified on the accompanying manifest or shipping paper.
(b)
The owner or operator must develop and follow a written waste analysis plan which
describes the procedures which he will carry out to comply with paragraph (a) of this section.
He must keep this plan at the facility. At a minimum, the plan must specify:
(1)
The parameters for which each hazardous waste, or non-hazardous waste if applicable under §264.113(d), will be analyzed and the rationale for the selection of these parameters (i.e., how analysis for these parameters will provide sufficient information on the waste’s
properties to comply with paragraph (a) of this section);
(2)
The test method which will be used to test for these parameters;
(3)
The sampling method which will be used to obtain a representative sample of the
waste to be analyzed. A representative sample may be obtained using either:
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(i)
ter; or
(ii)
One of the sampling methods described in Appendix I of Part 261 of this chapAn equivalent sampling method.
[Comment: See §260.21 of this chapter for related discussion.]
(4)
The frequency with which the initial analysis of the waste will be reviewed or
repeated to ensure that the analysis is accurate and up to date;
(5)
For off-site facilities, the waste analyses that hazardous waste generators have
agreed to supply; and
(6)
Where applicable, the methods which will be used to meet the additional waste
analysis requirements for specific waste management methods as specified in §§265.193,
265.225, 265.252, 265.273, 265.314, 265.375, 265.402, 254.1034(d), 254.1063(d), and
268.7 of this chapter.
(7)
For surface impoundments exempted from land disposal restrictions under
§268.4(a), the procedures and schedules for:
(i)
The sampling of impoundment contents;
(ii)
The analysis of test data; and
(iii) The annual removal of residues which are not delisted under §260.22 of this
chapter or which exhibit a characteristic of hazardous waste and either:
(A)
Do not meet applicable treatment standards of Part 268, Subpart D; or
(B)
Where no treatment standards have been established:
(1)
Such residues are prohibited from land disposal under §268.32 or RCRA section
2004(d); or
(2)
Such residues are prohibited from land disposal under §268.33(f).
(c)
For off-site facilities, the waste analysis plan required in paragraph (b) of this
section must also specify the procedures which will be used to inspect and, if necessary,
analyze each movement of hazardous waste received at the facility to ensure that it
matches the identity of the waste designated on the accompanying manifest or shipping
paper. At a minimum, the plan must describe:
(1)
The procedures which will be used to determine the identity of each movement
of waste managed at the facility; and
(2)
The sampling method which will be used to obtain a representative sample of
the waste to be identified, if the identification method includes sampling.
(3)
The procedures that the owner or operator of an off-site landfill receiving
containerized hazardous waste will use to determine whether a hazardous waste generator
or treater has added a biodegradable sorbent to the waste in the container.
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APPENDIX E
OVERVIEW OF MAJOR HAZARDOUS WASTE MANAGEMENT UNITS
Containers
Containers are portable devices used to treat, store, transport, dispose, and handle waste materials. They
include metal drums and pails, polyfiber bags, plastic drums and carboys, or durable fiberboard paper
drums or pails. They do not include tanks, which are regulated separately, as discussed below. Metal and
plastic drums and pails are the most commonly used containers; however, durable fiber drums (used most
often to store and transport solids designated for incineration) and drums constructed of other materials are
also widely used. Before selecting a container for storage or treatment of the waste, you should identify its
physical and chemical characteristics. The selection of waste analysis parameters will be dependent upon
the specific characteristics of the wastes you manage and the construction materials of the container used at
your facility. You should consider performing laboratory analysis on a sample of your wastes for parameters such as flash point, pH, reactivity, and moisture content.
Tanks
Tanks are stationary devices constructed primarily of non-earthen materials designed to contain an accumulation of hazardous waste(s). They do not have to be totally enclosed and they are generally distinguished from surface impoundments because they are self-supporting (i.e., they do not need external
support materials, such as earth). They are generally constructed of metal, fiberglass, or rugged plastics.
Surface Impoundments
Surface impoundments are natural depressions, man-made excavations, or diked areas, formed primarily of
earthen materials, used to contain an accumulation of liquids or wastes containing free liquids. Examples
of surface impoundments are ponds, lagoons, and holding, storage, settling and aeration pits. Surface
impoundments can be used as treatment, storage, or disposal units.
Although surface impoundments are constructed primarily of earthen materials, they often can have components made of synthetic materials, such as liners and leak detection systems. Synthetic materials that are
most often used in the construction of liners include high-density polyethylene, chlorinated polyethylene,
and polyvinyl chloride. Leak detection and leachate collection systems can be constructed from a number
of geosynthetic textile materials, including polyethylene, polypropylene, and polyester. Surface impoundments may be equipped with a variety of high-strength polymer plastic piping (e.g., polyvinyl chloride) to
aid in the removal of liquids that have accumulated in leachate collection systems, a component of the leak
detection system.
Landfills
Landfills are disposal units where hazardous wastes are placed in or directly on land. In the RCRA regulations, waste piles, surface impoundments, land treatment units, underground injection wells, salt dome
formations, mines, or caves are not regulated as landfills. Landfills are usually man-made excavations, but
their designs invariably include the use of synthetic materials for liners, caps, and leachate collection
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systems. These synthetic materials may include high-density polyethylene, chlorinated and sulfurated
polyethylene, polyvinyl chloride (PVC), and other geosynthetic textiles.
Containment Buildings
Containment buildings are enclosed structures used to store or treat hazardous waste. They must be
completely enclosed to prevent exposure to precipitation and wind, and be constructed of man-made
materials of sufficient strength and thickness to support themselves, the waste contents, and any personnel and heavy equipment that operate within the unit.
Wastes managed in containment buildings cannot be in liquid form (i.e., flow under their own weight to
fill the vessel in which they are placed, or be readily pumpable). Containment buildings must have a
primary barrier designed and constructed of materials to prevent hazardous wastes from being accidentally or deliberately placed on the land beneath or outside the unit. They must also have controls to
prevent fugitive dust emissions and the tracking of materials from the unit by personnel or equipment.
Containment buildings used to manage hazardous wastes containing free liquids must include a primary
barrier to prevent migration of hazardous constituents into the barrier and a liquid collection and removal system that will minimize the accumulation of liquid on the primary barrier; and be equipped
with secondary containment including (1) a secondary barrier and (2) a leak detection, collection, and
removal system. Under certain conditions, containment buildings may serve as secondary containment
for tanks placed within the containment building.
As with tanks and containers, generators may accumulate and treat their hazardous wastes within these
containment buildings without obtaining a RCRA Subtitle C permit. Generators treating hazardous
wastes in order to comply with the applicable land disposal restrictions treatment standards must develop and follow a written waste analysis plan.
Waste Piles
Waste piles are areas used for non-containerized storage or treatment of solid, non-flowing wastes on the
land. Waste piles are normally underlain by liners constructed of concrete or other materials, which act
as barriers to prevent direct contact of the waste with the soil below the unit. Waste piles that are protected from wind, precipitation, and surface water run-on, and that are not containment buildings, are
subject to reduced regulations. Waste piles and their associated liners and leak detection systems can be
constructed of synthetic materials, including high-density polyethylene and PVC for liners, and a number of different geosynthetic textiles (e.g., polyester polypropylene) for leak detection apparatus. Waste
piles also use a variety of high-strength polymer plastic pipes for the removal of leachate and other
liquids that have accumulated in leachate collection systems; these are often made of polyvinyl chloride.
Because of the impact of the Land Disposal Restriction program, most hazardous wastes cannot be
placed on a waste pile until they meet the applicable LDR treatment standards in 40 CFR Part 268,
Subpart D.
Land Treatment Units
Land treatment units are units where hazardous waste is applied or incorporated into the soil surface.
Land treatment units are typically units consisting of natural soils where natural biological and chemical
degradation and attenuation processes immobilize, transform, or degrade hazardous constituents over
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time. These soils are normally prepared in a manner that maximizes these reactions in the upper layers
of soil (the treatment zone), and minimizes processes that might inhibit beneficial reactions or result in
the release of hazardous constituents (such as surface water run-off). Because of the impact of the LDR
program, most hazardous wastes cannot be placed in a land treatment unit until they meet the applicable
LDR treatment standards, unless a no migration exemption has been granted under 40 CFR §268.6.
Incinerators
Incinerators are complex enclosed devices that use controlled flame combustion to treat hazardous
waste and render them less toxic or hazardous. Incinerators also use infrared radiation or plasma-arc
technology to incinerate wastes. Under RCRA, boilers, industrial furnaces, sludge dryers, and carbon
regeneration units are regulated separately from incinerators. Incinerators are usually constructed of
stainless steel or some other material that is resistant to both high temperatures and normal corrosion
processes.
Boilers and Industrial Furnaces
Boilers and industrial furnaces are devices that burn hazardous waste(s) primarily to recovery materials
or energy. These units differ from incinerators because they are not used solely to destroy wastes, but
instead process hazardous wastes for their heating value or material content. Boilers, which are enclosed devices that use controlled flame combustion, (1) have physical provisions to recover and export
thermal energy; (2) are designed with the combustion chamber and the energy recovery sections as one
unit; (3) have a thermal energy recovery efficiency of at least 60 percent; and (4) export and use at least
75 percent of recovered energy. Industrial furnaces are similar to boilers, but they may also be used to
recover materials, as well as energy. Examples of industrial furnaces include cement kilns, lime kilns,
aggregate kilns, coke ovens, blast furnaces, and smelting, melting, and refining furnaces. Boilers and
industrial furnaces are typically constructed of stainless steel or other non-corrosive materials to resist
the effects of heat and corrosives generated during the combustion process.
Miscellaneous Units
Miscellaneous units include a variety of types of units that are not covered by any other permit standards under RCRA. A miscellaneous unit is any unit that is used to treat, store, or dispose of hazardous
waste that is not otherwise regulated. Therefore, a miscellaneous unit is not: a container, tank, surface
impoundment, waste pile, land treatment unit, landfill, incinerator, boiler, industrial furnace, underground injection well, or a unit that qualifies for a permit as a research, development, or demonstration
unit. Examples of miscellaneous units include carbon regeneration units, open burning units, open
detonation units, and sludge dryers.
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APPENDIX F
GLOSSARY OF TERMS
Certification: A written statement of professional opinion and intent signed by an authorized representative that acknowledges an owner’s or operator’s compliance with applicable LDR requirements.
Certifications are required for treatment in surface impoundment exemption requests, applications for
case-by-case extensions to an effective date, no-migration petitions, and waste analysis and
recordkeeping provisions applicable to any person who generates, treats, stores, or disposes of hazardous wastes (excluding generators that do not treat on site and send waste off site to be treated). The
information referenced by the certification must be true, accurate, and complete. There are significant
penalties for submitting false information, including fines and imprisonment.
Disposal Facility: A facility or part of a facility at which hazardous waste is intentionally placed into
or on any land or water, and at which waste will remain after closure.
Extraction Procedure Toxicity Test: The Extraction Procedure Toxicity Test (EP Tox Test) was
used to determine if a waste exhibited the characteristics of toxicity. The EP Tox Test (method 1310
in EPA’s SW-846) was designed to assess the leaching potential of waste destined for land disposal.
It has now been replaced by the TCLP.
Facility: All contiguous land, structures, or other appurtenances, and improvements on the land, used
for treating, storing, or disposing of hazardous waste. A facility may consist of one or several treatment, storage, or disposal operational units (e.g., one or more landfills, surface impoundments, or
combinations of them).
Fingerprint Analysis: Sampling and analysis of several key chemical and physical parameters of a
waste to substantiate or verify the composition of a waste as determined previously during a full-scale
waste characterization. Fingerprint analysis is typically used by generators and off-site TSDFs to
expedite waste characterization of frequently generated or received wastes. Parameters for analysis
may be a subset of the parameters used during full-scale characterization, or they may be parameters
that are not normally present in the waste to verify the absence of certain constituents.
Generator: Any person, by site, whose act or process produces hazardous waste identified or listed
in Part 261 of RCRA or whose act first causes a hazardous waste to become subject to regulation.
Hazardous and Solid Waste Amendments (HSWA): Amendments to RCRA in 1984, that minimize the nation’s reliance on land disposal of hazardous waste by, among other things, requiring EPA
to evaluate all listed and characteristic hazardous wastes according to a strict schedule to determine
which wastes should be restricted from land disposal.
Hazardous Waste: Waste that, because of its quantity, concentration, or physical, chemical, or
infectious characteristics, may cause or significantly contribute to an increase in mortality or an
increase in serious irreversible, or incapacitating reversible, illness, or pose a substantial present or
potential hazard to human health or the environment when improperly treated, stored, transported,
or disposed of, or otherwise managed. Hazardous wastes are listed in 40 CFR Part 261 and/or
exhibit one of the four characteristics in 40 CFR Part 261 ( i.e., ignitability, corrosivity,
reactivity, and toxicity).
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Hazardous Waste Code: The number assigned by EPA to each hazardous waste listed in 40 CFR
Part 261, Subpart D, and to each characteristic waste identified in 40 CFR Part 261, Subpart C.
Interim Status: Provision of RCRA that allows a facility to operate without a permit provided 1) the
facility was in existence on November 19, 1980; 2) the facility is in existence on the effective date of
a new regulation that lists a waste as a hazardous waste or establishes a new characteristic of hazardous waste; or 3) the facility is in existence on the effective date of a new regulation that regulates a
hazardous waste management unit for the first time. In both circumstances, Part A of the permit
application must be submitted to EPA by a specified date (with Part B submitted voluntarily or
“called in” by EPA at a subsequent date). The intent of interim status is to allow a facility to continue to operate for a short time period pending approval of their permit application.
Lab Pack: A lab pack is an overpacked container, usually a steel or fiber drum, containing small
quantities of chemicals of the same hazardous class.
Land Disposal Restrictions: Provision of HSWA that prohibits the land disposal of hazardous
wastes into or on the land unless EPA finds that it will not endanger human health and the environment. EPA must develop levels or methods of treatment that substantially diminish the toxicity of
the waste or the likelihood that hazardous constituents will migrate from the waste that must be met
before the waste is land disposed. Strict statutory deadlines were imposed on EPA to regulate the
land disposal of specific hazardous wastes, concentrating first on the most harmful. EPA has met all
of the Congressionally mandated dates.
Notification: When restricted wastes are being shipped off-site for treatment, storage, disposal, or
are managed on-site, EPA has established a tracking system that requires that notifications and
certifications be sent to the receiving facility or if applicable to EPA or the appropriate EPA representative. These requirements are outlined in 40 CFR 268.7. For example, notification requirements
include the EPA Hazardous Waste Number, corresponding treatment standards or prohibition levels,
the manifest number, and waste analysis data.
Off-Site Facility: A facility that receives and manages hazardous waste from another facility that is
not geographically on site.
On-Site Facility: A facility that manages only those hazardous wastes that are generated on its own
geographic site.
Prohibited Wastes: Prohibited wastes are a subset of restricted wastes (under the LDR regulations)
that have established treatment standards but do not meet the respective treatment standards, nor have
a variance or waiver in effect and are, therefore, currently ineligible for land disposal.
RCRA Subtitle C Permit: An authorization via a permit from EPA that allows a facility to treat,
store, and/or dispose of hazardous wastes. The permit includes administrative requirements, and
facility operating and technical standards for each type of waste management unit that is being
permitted. [Facility owners/operators must submit a two-part (Part A and Part B) permit application
to obtain a permit.]
Resource Conservation and Recovery Act (RCRA): The Resource Conservation and Recovery
Act of 1976 regulates hazardous waste generation, storage, transportation, treatment, and disposal.
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The Act was amended three times: most significantly, on November 8, 1984. The 1984 amendments called HSWA significantly expanded the scope and requirements of RCRA.
Restricted Wastes: Restricted wastes are those RCRA hazardous wastes that are subject to the
LDR program. A waste is restricted if EPA has established a treatment standard for it, or if it has
been specifically designated by Congress as ineligible for land disposal. While some restricted
wastes may be eligible for land disposal without meeting treatment standards, all restricted wastes
are, at a minimum, subject to the waste analysis, notification, and recordkeeping requirements of 40
CFR §268.7.
Storage Facility: A facility that holds hazardous waste for a temporary period, at the end of which
the hazardous waste is treated, disposed of, or stored elsewhere.
Subtitle C Facility: A facility that manages hazardous wastes as defined by RCRA. These facilities may include disposal facilities (e.g., landfills, surface impoundments), treatment facilities, (e.g.,
incinerators) and storage facilities.
Subtitle D Facility: A facility which manages non-hazardous wastes as defined by RCRA. These
facilities may include disposal facilities (e.g., landfills), treatment facilities (e.g., incinerators), and
storage facilities.
Toxicity Characteristic Leaching Procedure (TCLP): The TCLP is designed to determine the
mobility of both organic and inorganic contaminants in liquids, solids, and multiphasic wastes.
Originally promulgated in the November 7, 1986 Solvents and Dioxins Rule, this testing procedure
was initiated for evaluation of the solvent- and dioxin-containing wastes prior to land disposal.
Effective September 25, 1990 (for large quantity generators), or March 29, 1991 (for small quantity
generators), the TCLP replaced the EP Tox Test for determining if a waste exhibits the hazardous
characteristic of toxicity. In addition, under the TCLP rule, 26 contaminants were added to the
original 14 contaminants subject to toxicity characteristic determination.
Transporter: A person engaged in the offsite transportation of hazardous waste by air, rail, highway, or water.
Treatment Facility: A facility that uses any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any
hazardous waste so as to neutralize such waste, or to render such waste either non-hazardous or less
hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or
reduced in volume.
Waste Analysis: Obtaining a detailed chemical and physical analysis of a representative sample of
a waste. The analysis may include data developed using sampling and laboratory analysis, as well
as existing published or documented data on the waste or on a waste generated from similar processes.
Waste Analysis Plan (WAP): Document describing the procedures that will be carried out at a
facility to meet waste analysis requirements.
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APPENDIX G
REFERENCES
1.
A Method for Determining the Compatibility of Hazardous Wastes, EPA-600/2-80-076, U.S.
Environmental Protection Agency, Cincinnati, Ohio, 1980. 149pp. Available from the National Technical Information Service (NTIS), PB80-221-005.
2.
Design and Development of a Hazardous Waste Reactivity Testing Protocol. EPA-600/5284-057, U.S. Environmental Protection Agency, Municipal Environmental Research Laboratory, Cincinnati, Ohio, 1984. Available from NTIS, PB84-158-807.
3.
Characterizing Heterogeneous Wastes: Methods and Recommendations. U.S. Environmental
Protection Agency, ORD, U.S. Department of Energy, EPA/600/R-92/033, February 1992.
Available from Environmental Research Information, Cincinnati, OH 45268.
4.
EPA Memorandum. “Guidance on Petroleum Refinery Waste Analyses for Land Treatment
Permit Application.” April 3, 1984.
5.
Guidance Manual for Hazardous Waste Incinerator Permits. SW-966, U.S. Environmental
Protection Agency, Washington, D.C., 1983. Available from NTIS, PB86-100-577.
6.
Hazardous Waste Land Treatment. SW-874, U.S. Environmental Protection Agency, Washington, D.C., 1983. 671 pp. Available from NTIS, PB89-179-014.
7.
Identification and Listing of Hazardous Waste Under RCRA, Subtitle C, Section 3001. Listing of Hazardous Waste (40 CFR 261.31 and 261.32). Available from NTIS, PB81-190035,
U.S. Environmental Protection Agency, Washington, D.C., 1980. 853 pp.
8.
Methods for Chemical Analysis of Water and Waste. U.S. Environmental Protection Agency,
Washington, D.C., 1983. EPA-60014-79-020.
9.
Permit Applicants’ Guidance Manual for the General Facility Standards of 40 CFR 264. SW968, U.S. Environmental Protection Agency, Washington, D.C., 1983. Available from NTIS,
PB87-151-064/AS.
10.
Permit Applicants’ Guidance Manual for Hazardous Waste Land Treatment, Storage, and
Disposal Facilities. SW-84-004, U.S. Environmental Protection Agency, Washington, D.C.,
1983. Available from NTIS, PB89-115-695.
11.
Standard Methods for the Examination of Water and Wastewater, 17th edition. American
Public Health Association, Washington, D.C., 1989. Available from the Water Pollution
Control Federation, Washington, D.C., #S0037.
12.
Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. SW-846, Third
Edition as amended by Update I, U.S. Environmental Protection Agency, Washington, D.C.,
1987. Available from NTIS, PB88-239-223.
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13.
Toxic and Hazardous Industrial Chemicals Safety Manual for Handling and Disposal with
Toxicity and Hazard Data. The International Technical Information Institute, Tokyo, Japan,
1976. 591 pp.
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